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Reverse mortgage question

Is counseling required for HECM to HECM refinances?

Sometimes. FHA lets counseling be waived on a HECM to HECM refinance, but only when every condition is met, including applying within five years of your original HECM's closing date and passing the five times cost test. Counseling can never be waived in 13 states, including California and Texas, even when FHA's conditions are met. And if the refinance adds a borrower or a non-borrowing spouse, counseling is required.

The old answer on our site was a simple "yes." The real answer is a little longer, and it depends on where you live and when you got your first HECM.

The short answer

Counseling can be waived on a HECM to HECM refinance, but only if every condition below is met, and only if your state allows it. Miss one, and you'll do counseling again. That isn't a bad thing. The program changes over time, and a refresher before you sign a new loan is worth an hour.

When counseling can be waived

FHA allows a waiver when all of these are true:

Your state allows it. See the list of 13 states below.
You're inside the five-year window. Your refinance application has to be no more than five years after the closing date of your first, original HECM. Not your most recent refinance. The clock doesn't restart after another refinance or another counseling session, and the lender has to document the original closing date.
You received the anti-churning disclosure. That's HUD's form 92901. It shows what the refinance costs and how much more money it opens up.
The refinance passes the five times test. The increase in your principal limit has to be at least five times the closing costs of the refinance. HUD has a newer cost test for the refinance itself, but it doesn't replace the five times test for the counseling waiver.
The spouse rules line up. If your original HECM's case number was assigned on or after August 4, 2014, you and any non-borrowing spouse must have received HECM counseling back then. If it was assigned before that date, there can't be a non-borrowing spouse under HUD's MOE assignment rules.
Nobody new is being added. If the refinance adds a borrower or a non-borrowing spouse, for example a spouse who just turned 62, counseling is required.

Your lender has to confirm you meet every one of these before counseling can be waived.

States where it can never be waived

Even when FHA's conditions are met, counseling can't be waived on a HECM to HECM refinance in these 13 states:

California
Connecticut
Delaware
Indiana
Massachusetts
Minnesota
New York
North Carolina
Pennsylvania
Rhode Island
Tennessee
Texas
Vermont

Two of those are states we work in. If your home is in California or Texas, plan on counseling. In California, the 7-day wait after counseling applies too. See Why do I need to wait 7 days after counseling?

Should you skip it even if you can?

My honest take: if you meet every waiver condition, great, it saves a little time. But if your situation has changed since your first HECM (a spouse, your health, your plans for the home), I'd do the session anyway. Our philosophy is the same as it's always been: you shouldn't learn anything new during counseling, and you shouldn't sign a new loan you don't fully understand.

What to do next

Before you refinance, I'll run the five times test with real closing costs and today's rates, and check the waiver conditions against your original loan. If the numbers don't justify it, I'll tell you. See Reverse Mortgage Refinance for when a refinance makes sense, or call us at 530-888-6000.

Sources

HUD Single Family Housing Policy Handbook 4000.1 (HECM refinance and counseling waiver): hud.gov
24 CFR Part 206, Home Equity Conversion Mortgage Insurance: ecfr.gov

ZYNG Mortgage, Inc., NMLS #76801. A reverse mortgage has no required monthly mortgage payments and uses your home's equity. Fees, mortgage insurance and other costs can be added to the loan balance, and the balance grows over time as interest is added, so your equity typically decreases. When the loan becomes due, the home may need to be sold, or the loan repaid from other funds. Interest is not tax-deductible until it is paid, in part or in full. You keep title to your home and must keep paying property taxes, homeowners insurance and upkeep, and meet the other loan terms; not doing so can make the loan due and could lead to foreclosure.

This material is not from HUD or FHA and was not approved by HUD or a government agency.

HECM count at the top of this page: HUD data through September 2026 (source, opens in a new tab).