Christy Hancock Quoted in Inside Mortgage Finance on Proposed Federal HEI Legislation

Bradley partner Christy Hancock was quoted in Inside Mortgage Finance on the proposed federal Home Equity Lending Integrity Act, which would bring home equity investment (HEI) products under the Truth in Lending Act (TILA) by classifying them as residential mortgage loans. If enacted, the legislation would direct the Consumer Financial Protection Bureau (CFPB) to establish regulations for these products.

“If they are successful in getting a definition added to TILA, then lenders would be able to look at their products — and of course, these products have different varieties to them — and it would be clearer that they do or don’t fall under TILA based on their terms,” Hancock said.

Hancock also emphasized that federal action is not the only path to greater oversight. Even if Congress does not advance the bill, she said, the CFPB could still pursue regulatory action.

“Since there is no federal rule on point right now, what you’re getting is a patchwork quilt of guidance out of the states, and that is where you get lots of uncertainty for the industry because two states right next to each other can have very different opinions on the products,” Hancock said.

Hancock and three other Bradley attorneys recently analyzed differing state approaches, noting that while several states, including Connecticut, Maine, North Carolina, and Pennsylvania, have applied existing mortgage or consumer credit laws to HEIs, Illinois has created a product-specific regulatory framework with unique requirements.

“The APR cap arguably reflects a legislative judgment that existing consumer protections are insufficient for these products,” the attorneys explained.

The full article, “HEI Legislation Under Consideration in Congress,” appeared in Inside Mortgage Finance’s Inside Nonconforming Markets, Issue 31:15, on July 17, 2026. (login required)