NCLC, on behalf of its low-income clients, submitted the below comments on the draft of the HECM Handbook, Section 4000.1. The reverse mortgage program was created by Congress to allow older homeowners to tap into their home equity without increasing the risk of displacement. In implementing the program, HUD is tasked with a dual mission of preserving stable homeownership for HECM borrowers, enabling them to age in place, while also protecting the MMI fund. All of the comments on the draft Handbook are intended to help HUD promote this dual purpose in its administration of the HECM program.