This is a letter on behalf of the National Consumer Law Center regarding the Urban Institute’s February 2026 research report (“Report”) on “shared equity products,” commonly known as “home equity investment loans” (“HEI loans”). We urge the Urban Institute to revise the Report to retract the inaccurate legal conclusions that HEI loans are not loans and can not be regulated under mortgage laws, and to provide, at minimum, an acknowledgement that the Report does not provide a meaningful examination of the critical issues described below regarding the risks of HEI loans for homeowners, including housing instability and home loss. The Report’s limitations include:
- lack of examination of the effects of HEI loans on homeowners after day one, including the Report’s failure to meaningfully address the CFPB and Washington state Report findings in this regard;
- lack of discussion of the emerging consensus among courts and state regulators that the product constitutes mortgage credit (and that the Report erred in stating that HEI loans are not mortgages); and
- an absence of any meaningful engagement on the question of how mortgage regulations can be applied to this product (in light of the fact that regulators and state legislatures are in fact applying mortgage regulations to them and the factors cited in the Report are not, in fact, barriers to mortgage regulation).
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