Hi Jennifer,

Good question, and the short answer is no - not for the same borrowers.

HUD requires that reverse mortgage counseling be completely independent from the origination process.  The whole point of the counseling requirement is to make sure borrowers get impartial advice from someone who has no financial stake in whether the loan closes.  An active MLO counseling their own clients would be a direct conflict of interest under HUD's rules.  That is not a gray area.

HUD also prohibits interested parties - which includes loan originators - from being present during counseling sessions or having any influence over the process.  So even if you got certified as a counselor, you could not counsel borrowers you are also originating loans for.

Can you do both jobs at the same time?

In theory, you could hold both roles - active MLO and HUD-approved counselor - but you would need to keep them completely separate.  You could counsel borrowers that you have no origination relationship with, and you could originate loans for borrowers counseled by someone else.  In practice, most people find that difficult to manage cleanly, and the liability exposure from any perceived conflict of interest is real.

If you want to pursue counseling:

To become a HUD-approved HECM counselor, you need to affiliate with a HUD-approved counseling agency, complete HUD's required training and certification, and pass the HUD Housing Counseling Certification Exam.  It is a legitimate career path, but it is a separate one from origination - not really something you can layer on top of an active origination practice without creating problems.

If your goal is to serve your reverse mortgage clients better, the more practical path is to deepen your knowledge on the origination side and ensure your borrowers are connected with strong, independent counselors from the start.

Reference: HUD Handbook 4000.1, Section II.B.1.e - Counseling Prohibited Practices (PDF page 542).