HECM At-Risk Extension: Eligibility, Filing, and Duration

The HECM At-Risk extension is a HUD policy that lets a mortgage servicer delay foreclosure on a Home Equity Conversion Mortgage when the borrower is at least 80 years old, still lives in the home, and faces a terminal illness, long-term disability, or critical caregiving situation that would make relocation dangerous. Under FHA Servicing Guide rules effective April 29, 2024, an approved extension stays in place for as long as the qualifying borrower keeps living in the property, with no annual recertification.¹ The extension only applies when the loan became due and payable because of unpaid property charges, and the servicer must rule out a repayment plan before considering it.

Who Qualifies

Three conditions have to line up: age, occupancy, and a critical hardship.

The age threshold is measured from the youngest living borrower on the loan. If two people are on the HECM, both must be at least 80, because HUD looks to the younger one. There is no “close enough” allowance for someone approaching 80.²

The borrower has to still occupy the property as a principal residence. HUD does not fix a specific number of days per year in the At-Risk guidance, but extended stays at a second home or in a care facility can disqualify the borrower.³

The critical circumstance has to fit one of three narrow categories defined in Mortgagee Letter 2015-11 and carried forward through Mortgagee Letter 2023-23:²

A terminal illness that a physician can document as life-threatening, where the stress and disruption of relocation would endanger the borrower’s health or survival.
A substantiated long-term physical disability severe enough that moving would present a serious risk to the borrower’s well-being, not a temporary condition expected to improve.
A unique occupancy need, such as a terminally ill family member receiving care in the residence.

General claims of frailty or old age will not clear the bar. The physician’s statement has to tie a specific diagnosis to the specific danger relocation would cause.

When the Extension Applies

The At-Risk extension is only relevant when a HECM has become due and payable because of unpaid property charges — property taxes, homeowner’s insurance, HOA fees, or required maintenance. A HECM has no monthly loan payment, but the borrower has to keep up with those charges. When they go unpaid and the loan’s available credit can no longer cover them, the servicer submits a due-and-payable request to HUD, and the debt accelerates toward foreclosure unless loss mitigation steps in.³

The extension does not apply if the loan came due because the borrower moved out, transferred title, or died. Those situations follow different procedures.

It also is not the first tool the servicer reaches for. Servicers must first evaluate whether the borrower can handle a repayment plan to catch up on overdue charges. Only when a repayment plan is unavailable, has been declined, or has already failed does the At-Risk analysis begin.² Under Mortgagee Letter 2023-23, if the borrower’s surplus income is too low to support a reasonable repayment plan, or a recalculated plan after a failure would still produce unreasonable payments, the servicer may move directly to the At-Risk evaluation.⁴

Bringing income documentation and a clear picture of monthly expenses to that first conversation speeds the repayment analysis and shortens the path to the At-Risk review if a repayment plan really is not workable.

Documentation to Gather

There is no standard “At-Risk application form” the borrower requests from HUD. The process runs through the servicer’s own intake, so the first step is asking your servicer what they need. Across servicers, the same categories of evidence come up:

Proof of age for the youngest borrower: government-issued photo ID, birth certificate, or passport.
Proof of occupancy: recent utility bills, property tax statements, or voter registration tied to the property.
Medical documentation: a written statement from a licensed physician with the diagnosis, prognosis, and specific reasons relocation would endanger the borrower’s health or life. Letters that say only that the patient “should not be moved,” with no clinical detail, are routinely rejected.
Financial records: at least two months of bank statements, recent tax returns, and a breakdown of monthly income against expenses, supporting the finding that a repayment plan is not feasible.

When writing any narrative for the file, tie dates to events. “I was diagnosed with congestive heart failure in March 2025, which led to hospitalization, loss of part-time income, and inability to pay property taxes starting in the fourth quarter” tells the reviewer exactly how the hardship produced the default. Keep copies of everything you send.

How to Submit the Request

Documentation goes to the mortgage servicer, not to HUD directly. Certified mail with a return receipt gives you a paper trail, though many servicers now accept submissions through secure online portals. The servicer reviews the package, evaluates the criteria, and makes a recommendation to HUD, which holds final approval authority.

Servicers generally pause foreclosure activity during the review. If HUD denies the request, the borrower may have a limited window to supply additional documentation addressing the identified deficiency. A denial can restart the foreclosure clock quickly, so accuracy in the initial submission matters more than speed.

How Long the Extension Lasts

Once approved, the extension continues as long as the qualifying borrower keeps living in the home. The old annual recertification requirement was removed under the 2024 FHA Servicing Guide update, so borrowers no longer have to reprove their circumstances every year.¹

The extension delays foreclosure. It does not forgive debt. Interest and monthly mortgage insurance premiums keep accruing on the outstanding balance, and servicing charges stay in effect.⁵ The borrower also remains responsible for new property taxes, homeowner’s insurance, and other property charges that come due during the extension period.⁶ Falling behind again on those ongoing obligations can create a fresh default.

What Happens to a Spouse or Heirs

The At-Risk extension attaches to the qualifying borrower. It does not extend to a non-borrowing spouse. Mortgagee Letter 2015-11 states that nothing in the At-Risk guidance confers any right on a non-borrowing spouse to any action by HUD or the servicer.² A non-borrowing spouse may have separate protections under the HECM Deferral Period rules, but those run on different criteria and are not part of this program; a HUD-approved housing counselor can explain which, if any, apply.

When the last surviving borrower dies during the extension, it ends immediately and the loan reverts to standard due-and-payable procedures. Heirs do not inherit the extension. They may qualify for limited foreclosure extensions, typically two 90-day periods, but only by showing they are actively marketing the property, arranging financing, or sourcing funds to pay off the loan. HUD does not grant extensions simply to allow time for probate.

Options If You Are Not Yet 80

Borrowers who have defaulted on property charges but have not reached 80 cannot use the At-Risk extension. The primary alternative is a repayment plan, structured by the servicer to bring overdue charges current over time based on the borrower’s income, expenses, and arrearage. Terms vary by servicer.

Other paths that can help forestall foreclosure at any age include refinancing the defaulted HECM into a new HECM, using family resources to pay down the arrearage, and tapping local assistance programs that help seniors cover property taxes. Many states and counties offer property tax exemptions, deferrals, or freezes for older homeowners that can reduce the charges triggering the default in the first place. A HUD-approved housing counseling agency can help identify programs in your area at no cost.

1
Administration for Community Living. New Protections for Older Homeowners with HECM Reverse Mortgages
2
U.S. Department of Housing and Urban Development. Mortgagee Letter 2015-11 – Loss Mitigation Guidance for Home Equity Conversion Mortgages in Default Due to Unpaid Property Charges
3
U.S. Department of Housing and Urban Development. Mortgagee Letter 2016-07 – Expanded Permissive Loss Mitigation for Home Equity Conversion Mortgages
4
U.S. Department of Housing and Urban Development. Mortgagee Letter 2023-23 – Updates to the Home Equity Conversion Mortgage Program
5
eCFR. Home Equity Conversion Mortgage Insurance
6
U.S. Department of Housing and Urban Development. HECM Financial Assessment and Property Charge Guide