A reverse-mortgage second opinion is an independent review of another originator’s written proposal. It compares the Loan Estimate to HUD’s cost rules, checks HECM versus proprietary fit, and looks for counseling-avoidance or investment pitches. It is not a promise that you will get more money.
Jay Zayer, a Certified Reverse Mortgage Professional licensed in California and Arizona, works with multiple lenders. I will not open this conversation with “switch to me, I am the best.” A HECM is FHA-insured. It is not a government benefit, and a second opinion is not a HUD form.
Suppose you already have a reverse-mortgage proposal: a Loan Estimate, a napkin, or a sales script that never produced either. The useful file is the LE. TILA wants that disclosure so you can compare. Bring it. If the first originator will not issue one, that fact is already the review.
What should a second opinion actually open on the Loan Estimate?
Cost first, then product, then process.
On a HECM, initial MIP is 2.00% of maximum claim amount for every case (Mortgagee Letter 2017-12, case numbers on or after 2 October 2017). It is not a discount when first-year draws stay under the 24 CFR 206.25 cap. Annual MIP is 0.50% of the outstanding balance. Origination is capped by 24 CFR 206.31: the greater of $2,500 or 2% of the first $200,000 of claim amount plus 1% of the remainder, not more than $6,000 unless the Commissioner raises the cap. If the LE shows origination above that cap on a HECM, the review is over. Walk.
Third-party fees — appraisal, title, recording, counseling — should be itemized. Counseling typically costs $125 to $175. The certificate is valid for 180 days. A line that hides those items inside a single “closing cost” blob is a reason to ask again, not a reason to sign.
Price the same house so you can see whether the LE’s cash at closing is even in the HUD range. I do not publish a live principal-limit percentage. Illustrations on this site use a 7.000% expected rate, as of 22 September 2026. The 2026 HECM claim-amount cap is $1,249,125 (Mortgagee Letter 2025-22).
TILA’s Loan Estimate is a comparison tool. It is not an approval. A second LE from a second originator is how you use that tool. Asking me to bless a verbal number is not.
How do you tell a HECM cost stack from a proprietary pitch?
A HECM uses Mortgagee Letter 2017-12 MIP and 24 CFR 206.31. A proprietary reverse mortgage is a private note. It does not charge FHA initial MIP. It also does not import 24 CFR 206.31 unless the lender chooses to mirror it. A $20,000 origination on a private loan can be contractual and still be a reason to leave.
California proprietary programs that start at 55 — HomeSafe, Longbridge Platinum, Finance of America, and Mutual of Omaha Secure Equity among the ones I originate — can be the right box when age or the claim-amount cap is the HECM blocker. They can also be the wrong box when the first originator steered a 68-year-old on a $600,000 house into a private note to raise a fee. Compare both on paper.
Ask whether unused funds grow, whether a surviving spouse has a deferral clause, and whether non-recourse language is in the contract. 24 CFR 206.27(b)(8) does not automatically travel. If the first proposal never mentioned HECM versus proprietary on a high-value house, that omission is part of the review.
See scam warning signs and the longer scams article when the proposal includes a contractor tie-in, a deed request, or an investment pitch. CFPB has warned against using reverse-mortgage proceeds to buy investments or annuities. A second opinion that “improves” the file by adding an annuity is not an improvement.
Which proposal red flags are about process, not just price?
Counseling-avoidance. 24 CFR 206.41 requires HUD-approved counseling. In California, Civil Code section 1923.2(j) requires a list of at least ten agencies, and 1923.2(k) requires seven days after counseling before a complete application. An originator who says you can skip the session, use their cousin, or apply tomorrow morning in California is not a pricing issue. It is a walk-away.
Investment pitches tied to the loan. If the first meeting spent more time on a market-linked product than on occupancy, taxes, and the due-and-payable events in 24 CFR 206.27, the second opinion should say so.
Guaranteed approval or guaranteed proceeds. Nobody can give those. A HECM still needs age, title, occupancy, counseling, a financial assessment (Mortgagee Letters 2014-21 and 2014-22), and an appraisal.
A missing HECM-versus-proprietary comparison on a house near or above the 2026 cap. That is an evaluation failure, not a personality clash.
Questions to take back to any originator, including me, live on questions to ask a reverse-mortgage advisor.
What can go wrong: you treat the second opinion as a bidding war on a verbal principal limit. Two originators then inflate a number that no LE supports.
Who should not ask for a second opinion yet?
This review does not help a shopper who wants a verbal “you will get more” without a competing Loan Estimate. Bring the first LE, or get one issued. I will not invent a higher figure to win the file.
It does not help someone who wants me to “go after” a closed loan as litigation counsel. I can point to state regulators and CFPB’s complaint system. I am not the prosecutor. TILA rescission on a refinance of a principal dwelling is three business days (12 CFR 1026.23). After that, complaints and, if facts support it, an attorney.
A follow-up: does a second opinion restart California’s seven-day wait? The statute attaches to counseling and application, not to my reading of someone else’s LE. If you later apply with a different lender, that lender’s file still has to satisfy Civil Code section 1923.2 and 24 CFR 206.41. Arizona skips 1923.2(k) and still needs counseling.
Another follow-up: if the first LE is clean, should you still switch? Only if product fit is wrong — HECM versus proprietary, first lien versus reverse second, or a payment plan that does not match the goal. Switching for a logo is not a reason. I will say that even when the other logo could have been mine.
I work with multiple lenders. The second opinion is a comparison. It is not a recruitment speech. If the first file is already the right product at HUD’s published costs, stay. If it is not, fix the product or walk. Do not sign a napkin.