And proprietary reverse mortgages don't even exist anymore. Personally, I try to spend my energy working on stuff that actually exists today. Yes, Jumbo's will come back one day in the future, but they weren't that bad when they used to be available because their fundmentals were the same as HECM's.

Before all the Jumbo programs went away, I specialized in that market and I learned several things:

1. The consumer is very different. They're very sensitive to Estate Planning issues and ask questions that are way different then my average HECM consumer. The Jumbo consumer crosses their t's and dots all the i's. The research they apply prior to making a final decision is extensive and exhaustive.

2. The counseling session for Jumbo's is just as comprehensive as counseling for HECM's.

3. All the proprietary programs mimicked the HECM in most manners, but each program had a special feature that made it stand out and useful for specific purposes (ie: second home, co-ops, etc.)

4. The primary difference between HECM's and Jumbo's is the interest rate and loan fees. Jumbo's had a higher interest rate, to offset the risk of not being insured, and the fees were much lower – with some programs offering no fees.

>>“FTC staff believes that the Proposed Guidance addresses important issues related to reverse mortgages and does so at a critical juncture,” said the agency in its comments. “Reverse mortgage products have become more prevalent in recent years, and during an economic downturn even more elderly consumers may seek to use such products to obtain funds they sorely need.”

That statement makes me think they're not talking about proprietary programs, because it says Reverse Mortgage products have become more prevalent in recent years, yet all the Jumbo's have disappeared in recent years.

As far as the cross selling article last week, it's something that Jeff Lewis said and we covered it.

Last week the RMD article on cross-selling stirred up an interesting but somewhat disturbing discussion. In rereading the concerns of the FFIEC, after consumer ignorance about the products, inadequate counseling on proprietary products, and inability to pay real estate and insurance, their number four concern is cross-selling.

We do not seem to get it. Cross-selling is the biggest vulnerability we have as originators but many of those who are licensed to sell such products just don't seem to get it. It is not just your peers who are expressing concern; it is Congress, regulators, and state legislators but they are not alone.

Financial product and insurance licensed HECM originators, it is your peers who are concerned that your loud protests over cross selling prohibitions will stir up more problems for the industry. Please tone it down. Not all of us are crying out for originators to be able to cross sell but there is a significant group of you who seem to show no fear of incurring the wrath of lawmakers or regulators in pushing their agenda.

Please just learn to make a choice. Either provide a senior with a HECM or sell your wares; just don't push or try to do both.