Maine and the SHARE Act Draw a Bright Line for HEIs

Maine just did the home equity market a favor.
With LD 1901, Governor Janet Mills signed the first state law in the country aimed specifically at protecting homeowners from home equity investment agreements. NCLC called it “the most comprehensive set of protections in the country”, and the law does something especially important: it stops pretending these products are something other than mortgage credit. Maine treats shared appreciation mortgage loans as the mortgage loans they are and subjects them to real consumer-finance rules.
That is the right move. For too long, a category of companies has tried to market HEIs as “investments” when, in substance, they function like high-cost, high-risk loans secured by a family’s home. NCLC’s March 2026 brief says exactly that: HEIs are loans in substance, even while companies use labels like “investment” or “option” to sidestep the protections that normally apply to mortgage credit. And all of this is before you look at the details of the investment itself, which is often bad for the homeowner while claiming the exact opposite.
The CFPB’s 2025 market overview puts even finer detail on the problem. It found that many HEI contracts use their own proprietary payoff formulas built around multipliers, discounted starting home values, and rate caps that are mathematically equivalent to steep interest charges. It also noted processing fees are often 3% to 5% of the initial payment, and that the repayment obligation can become so large that a homeowner may need to sell the house or face foreclosure to satisfy it.
That is exactly why this moment matters for us at Homium.
Homium is not that.
I have said for years that Homium is the exception to extractive HEIs, reverse mortgages, and other subprime-style products that turn a homeowner’s need for liquidity into an opportunity to strip equity. Maine’s law makes the difference easier to see, and the new federal SHARE Act introduced by Congressman Blake Moore (UT) points in the same direction.
The difference starts with the math
Many HEIs are hard to understand because the math is designed to be hard to understand. A homeowner may receive 10% of the home’s value and later owe 20% of the home’s value because a company applied a 2x multiplier to the terms at the beginning. Or the company may set the home’s starting value 25% below the actual appraised value, so the company wins pretty much no matter what (and the homeowner loses). CFPB described both structures, and noted that in some scenarios the effective cost can behave like 20%-plus annual interest in the early years.
Homium does not do that. Our model is fair shared appreciation. If we provide 20% of the home’s value, we are repaid 20% of the value at payoff. No discounted starting appraisal. No multiplier. No black-box settlement formula. No hidden math meant to make the homeowner’s payoff bigger than the deal they thought they signed. Even the CFPB, in discussing the HEI market, noted that a few shared-equity programs are true 1:1 sales of home value and cited Homium as an example.
Then look at valuation
The HEI market has too often depended on valuation games. CFPB explicitly flagged discounted starting values as a way some companies ensure they come out ahead. Maine responded by requiring appraisal independence standards, quality controls for valuation models, and by limiting settlement payment to the appraisal at settlement rather than letting lenders layer on extra condition-based charges.
That is the right framework, and it fits the way we think this market should work. Homium uses standard appraisal and mortgage-lending processes, not engineered valuation discounts. Our whole point is to align with the homeowner’s real economics, not manufacture upside through appraisal mechanics.
Then look at documents, disclosures, and distribution
The problem with many HEIs is not only that the payoff is expensive. It is that the homeowner often cannot really compare the cost at origination. NCLC’s brief says HEIs obscure true cost by avoiding APR disclosure and burden consumers with complexity, while CFPB found that each company uses its own calculation method, making comparison difficult. Their answer was to require robust disclosures, a 3-day rescission right, HUD- or agency-approved counseling, and even annualized-cost, equity-share, settlement-payment, and APR disclosures for each year of the loan term based on an index prescribed by the state.
That is much closer to the Homium worldview than to the HEI playbook. Our product is a closed-end second mortgage, offered through mortgage originators, with simple and transparent terms. We built Homium to live inside normal mortgage accountability, not outside it. That is why our documents are meant to read like mortgage documents and why our product is designed to be understandable at closing and predictable at payoff.
Then look at borrower rights
Maine’s law bars prepayment penalties, protects ordinary rate-and-term refinancing, prohibits mandatory arbitration, imposes assignee liability, requires periodic statements and payoff-process notices, and creates a strong presumption of unconscionability or unfairness if the borrower did not have independent counsel. Those are serious consumer protections, and they tell you exactly what lawmakers are worried about in the HEI market.
I welcome that clarity, in fact, we’ve been begging for it. Good regulation should make it obvious which products benefit homeowners and create opportunity, and which are extractive and make things worse. Homium has always been built on the belief that homeowner-aligned shared appreciation should be transparent, accountable, and fair enough to survive real scrutiny.
The SHARE Act points to the scalable answer
Congress is also confirming that full disclosure and consumer protection are the right way to work with homeowner equity financing.
In March, Representatives Blake Moore, Andy Barr, and Jimmy Panetta introduced H.R. 8116, the Shared Home Appreciation for Residential Equity (SHARE) Act. The bill would encourage private capital to fund shared appreciation mortgages (not HEIs) by excluding certain proceeds from gross income. When these products are offered as part of a down payment assistance or other homeowner-focused program, they do tremendous good. Attracting more capital from private investors while maintaining consumer protections will expand these programs and help more Americans. But the key point is that the tax benefit is not open-ended. It is limited to SAMs used for down payment assistance to households at or below 140% of area median income, on primary residences only, with no interest and no monthly payment obligation. It also requires that the repayment percentage not exceed the percentage of the home value originally financed, caps the SAM at 49% of purchase price, and requires a qualified-mortgage first lien ahead of it.
That is not Congress endorsing an opaque HEI model. That is Congress signaling a preference for fair, transparent, 1:1 shared appreciation loan structures that can scale responsibly. The SHARE Act is effectively saying: if private capital is going to flow into this space, it should flow into the kind of product that lowers the monthly burden for working families, stays subordinate to a standard first mortgage, and keeps repayment tied to the same share that was originally provided. That is our format.
And this is not theoretical. The Michigan State Housing Development Authority is already partnering with the Tobias Harris Homeownership Initiative, Guild Mortgage, and Homium on a pilot that offers up to 40% down payment assistance through shared appreciation without adding monthly debt. Utah Dream Fund likewise uses Homium SAMs, describes the model as fair and transparent, and serves working families up to 140% of AMI. These are precisely the kinds of programs that show fair shared appreciation is both scalable and institutionally credible.
Clearer rules will help the right products win
That is my takeaway from Maine, and it is my takeaway from the SHARE Act.
When lawmakers and regulators clear the air, the distinction becomes obvious. On one side are HEIs that rely on discounted appraisals, multipliers, hidden fees, opaque payoff math, and legal theories designed to escape mortgage rules. On the other side are fair shared appreciation mortgages that use normal mortgage channels, align repayment to the share actually advanced, preserve borrower dignity, and can attract serious capital at scale.
I believe fair shared appreciation is the future. Maine’s law helps expose what is extractive. The SHARE Act helps point toward what is scalable. And Homium exists to prove that homeowner-aligned shared appreciation can be both.


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