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Unison Home Equity Review: 15 CFPB Complaints, 4 Lawsuits (2026)

By Jorge··22 min read

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Quick Answer

As of November 11, 2026, Unison (Real Estate Equity Exchange, Inc. d/b/a Unison, San Francisco) is still originating home equity sharing agreements, and the CFPB database lists exactly 15 complaints under that name, the latest received on May 27, 2026. Its home page, captured October 1, 2026, still shows “Prequalify now” and promises “zero monthly payments for up to 30 years.” The SEC-filed diligence guidelines (Opus Capital Markets, June 8, 2026) give the settlement formula: (current value minus Original Agreed Value) times the Investor Percentage, plus the amount advanced, with the Original Agreed Value set at 97.5% of the appraisal from October 2020 and 95% from February 15, 2023. In our worked example (our arithmetic, using the 4x pricing a third-party review reports), a $100,000 advance on a home that never changes in value is repaid with $120,000; at 3% a year the payoff is $157,091 in year 3, $257,567 in year 10 and $690,905 in year 30. Four lawsuits filed since December 2022 allege the product is an unlicensed mortgage (allegations, not findings).

Key Takeaways

  • The CFPB database holds 15 complaints under “Real Estate Equity Exchange, Inc. d/b/a Unison” (pulled November 11, 2026): 1 in 2022, 4 in 2023, 4 in 2024, 3 in 2025 and 3 in 2026 through May 27. Seven are about “Trouble during payment process,” 14 were closed with explanation and 1 with non-monetary relief; none carries a published narrative.
  • Still originating: Unison Trust 2026-2, reviewed June 8, 2026, drew 377 loans out of a 1,294-loan data tape, and the guidelines were changed on April 27, 2026 to stop allowing investment properties. Six securitization diligence reports filed since October 13, 2023 reviewed samples of 308, 296, 345, 257, 315 and 356 contracts.
  • The formula: the homeowner's payoff is the advance plus the Investor Percentage of the change in value measured from the Original Agreed Value. The risk adjustment that sets that starting point went from 2.5% to 5% on February 15, 2023 and the origination fee from 3% to 3.9% on June 6, 2023; the maximum Investor Percentage went from 70% to 60% on June 6, 2023.
  • In the June 2026 pool sample of 356 contracts, the Investor Percentage runs from 20.00% to 70.00% with a median of 68.37%, and 169 contracts sit at exactly 70.00% (our arithmetic from SEC Exhibit 99.2).
  • Courts: the Ninth Circuit reversed the dismissal of Washington consumer-protection claims on August 7, 2025 (unpublished); HousingWire reports Unison settled that case in October 2025. Since then, suits were filed in the D.C. Superior Court (February 11, 2026), the District of Colorado (April 6, 2026) and, as a consolidated class complaint, in San Francisco (May 22, 2026). These are allegations.

CSV · 149 rows

Unison: CFPB complaints, SEC filings, contract formula, court record and a $100,000 cost example

149 rows: 15 CFPB complaints by year, issue and response, nine Form D filings, six securitization diligence reports, the payoff formula and guideline changes read from SEC exhibits, the lawsuits, and nine cost scenarios. One source per row.

What Unison is, and what we could and could not read

Unison is a San Francisco company that pays a homeowner cash today in exchange for a share of the home's future change in value, with no monthly payment. Its home page, as the Internet Archive captured it on October 1, 2026, shows “20 years” of “Modernizing home equity finance,” more than 17,000 homeowners and $1.02 billion of “Home wealth unlocked” (the company's own claims). The legal entities, as the May 2026 class complaint lists them, are Unison Agreement Corporation, which signs the homeowner agreement, its parent Real Estate Equity Exchange, Inc. d/b/a Unison, and Unison Investment Management, LLC, which runs the funds. Our home equity investment contracts page covers the whole category and our Hometap review does the same exercise for its main rival.

What we read: the CFPB complaint database, SEC EDGAR (Forms D and ABS-15G), the Ninth Circuit memorandum, the consolidated class complaint filed in San Francisco, an AARP press release, and the Internet Archive capture of Unison's home page. What we could not read on November 11, 2026: Unison's FAQ, pricing and license pages (the site blocked our requests and the Internet Archive refused them), NMLS Consumer Access, and the court dockets. Where a term below comes from a third-party review it says so, and that is why this page does not score the cost example.

How the contract pays out

The best public description of a signed contract is a court's. In Homeowners v. Unison Agreement Corp. (Ninth Circuit No. 23-2835), a Washington couple signed on March 26, 2019 a “HomeOwner Agreement” under which Unison advanced $64,750 in exchange for an option to buy a 70.00% ownership interest in their $370,000 home for another $194,250, which is 3.0 times the advance; the couple also paid $2,525 in fees. If the home had been appraised at $518,000 when Unison exercised the option, the 70% interest would be worth $362,600, so Unison would net $168,350 on its $64,750. The option can be exercised at the 30-year expiration, a sale, the death of the last owner or an uncured default. After the third anniversary the homeowner can end the contract without selling only by paying a “Special Termination Price,” the greater of the advance plus accrued amounts or what Unison would get in a sale.

Unison's securitization reviewer prints the same economics as a formula. In Exhibit 99.1 of the Unison Trust 2026-2 filing (June 10, 2026): “Intrinsic Value = (Current AVM - Original Agreed Value) * Investor Percentage + OIP,” where OIP is the original investment price, and “Investor Percentage = Investment as Percent of Property * Pricing Ratio.” The rules behind the formula have moved:

Guideline changes printed in the SEC filing (Opus Capital Markets, June 8, 2026)

EffectiveChangeWhat it does to a homeowner (our reading)
April 2019 to April 2022Maximum Investment as % of Property 20.0%; maximum share of price appreciation 70%; minimum US FICO 620; owner-occupied debt limit 75%The investment could be 20% of the home and Unison's share of the change up to 70%
October 2020Original Agreed Value = Property Value at Origination * 97.5%Unison's share of the change starts 2.5% below the appraisal
February 15, 2023Risk adjustment “increased from 2.5% to 5%”; “No buyout restriction during program floor”; Equity Appreciation limit with a “Maximum Appreciation Factor - 20%”Starting point drops to 95% of the appraisal; the 20% limit is not defined in the filing
June 6, 2023Origination fee “increased from 3% to 3.9%”; Max Investor Percentage “changed from 70% to 60%”Higher fee, lower maximum share
March 7, 2026PACE liens are not eligible senior liensHomes with a PACE lien do not qualify
April 27, 2026“No longer allow investment properties”Owner-occupied homes only

What a homeowner pays at the end, per the formula, is the advance plus a share of the gain. The risk adjustment matters even when nothing happens to the house. At the 4x pricing a third-party review reports (Finder, updated September 21, 2026: “typically four times that percentage of your home's future change in value”), the payoff on a flat home is the advance times 1 plus 4 times the risk adjustment (our arithmetic):

What a flat house costs under each version of the starting point (our arithmetic)

Original Agreed ValueApplies fromPayoff on a $100,000 advance, home unchangedMultiple of the advance
100% of appraisalContracts such as the 2019 agreement in Ninth Circuit No. 23-2835 (their $370,000 value was the starting point)$100,0001.00x
97.5% of appraisalOctober 2020$110,0001.10x
95% of appraisalFebruary 15, 2023$120,0001.20x

That contract's 70% on a 17.5% investment (64,750 over 370,000) is the same 4.0 multiple (our arithmetic). Under the post-June 2023 maximum of 60%, an investment of 15% of the home's value reaches the cap at the same multiple; Finder reports 15% of home value, $30,000 to $500,000, 3.9% fee, a 620 minimum credit score and a 5% reduction as Unison's current terms.

What $100,000 costs in year 3, 10 and 30

We take an advance of $100,000 on an $800,000 home (12.5% of value), pricing at 4x, so an Investor Percentage of 50%, a starting point of $760,000 (95% of the appraisal) and the 3.9% fee ($3,900), leaving $96,100 before the appraisal ($450 to $1,250), inspection ($650 to $1,050) and settlement costs ($700 to $1,750) that Finder lists. The payoff is $100,000 plus 50% of the home value above $760,000. The same table holds for any home size at 4x, because the result is the advance times 1 plus 4 times (value now over value then, minus 0.95).

Payoff on a $100,000 advance on an $800,000 home (our arithmetic)

Settle inHome growsHome valuePayoff to UnisonMultiple of $100,000Annualized on $96,100
Year 30% a year$800,000$120,0001.20x7.7%
Year 33% a year$874,182$157,0911.57x17.8%
Year 36% a year$952,813$196,4061.96x26.9%
Year 100% a year$800,000$120,0001.20x2.2%
Year 103% a year$1,075,133$257,5672.58x10.4%
Year 106% a year$1,432,678$436,3394.36x16.3%
Year 300% a year$800,000$120,0001.20x0.7%
Year 303% a year$1,941,810$690,9056.91x6.8%
Year 306% a year$4,594,793$2,017,39620.17x10.7%

Three limits on this table. It leaves out the deferred maintenance adjustment and the 20% “Maximum Appreciation Factor,” which the filing does not define, so a limit of that kind would lower the high-growth rows. The first five years carry a restriction period in which, per Finder, Unison does not share in a decline; at 0% or more growth that does not matter. And a 6% rise for 30 years is a scenario, not a forecast. We did not compare a HELOC because we have no sourced rate to attach to this homeowner; our Figure HELOC review has 2025 median HELOC rates from HMDA, and a reverse mortgage has its own federal rules.

The class complaint of May 22, 2026 puts the formula in two homeowners' dollars (allegations). For one plaintiff it says Unison told him in December 2024 that “to remove the mortgage on his home, he would need to pay Unison $184,537”: the home estimated at $465,000, times 70%, minus a “Purchase Price Balance” of $140,963, after an advance of $46,987 about seven years earlier.

CFPB complaints: 15, by year and issue

The CFPB complaint database lists the company as “Real Estate Equity Exchange, Inc. d/b/a Unison.” We pulled every complaint under that name on November 11, 2026 at 20:32 UTC through the public API: 15, the latest received May 27, 2026. A second search of the database for the word “unison” in the company field returned the same 15 (company-name matches only). The database does not publish narratives for these complaints, so we can say what was classified, not what happened.

CFPB complaints under Unison's listed name (pulled November 11, 2026)

CutCount
Received 2022 / 2023 / 2024 / 2025 / 2026 (to May 27)1 / 4 / 4 / 3 / 3
Issue: Trouble during payment process7
Issue: Applying for a mortgage or refinancing an existing mortgage4
Issue: Confusing or misleading advertising or marketing; Confusing or missing disclosures; Struggling to pay mortgage; Closing on a mortgage1 each
Product: Mortgage (sub-products Other type of mortgage 8, HELOC 3, VA mortgage 1, Reverse mortgage 1) / Payday, title, personal or advance loan (Other advances of future income 2)13 / 2
Company response: Closed with explanation / Closed with non-monetary relief14 / 1
Largest states: California 4, Florida 3, New Jersey 2, North Carolina 211 of 15
Tagged Older American (alone or with Servicemember)6 of 15
Submitted by web / phone / postal mail11 / 2 / 2

Fifteen is a small number for a company that says it has 17,000 homeowners, and it does not mean the contracts are free of dispute: the plaintiffs in the cases below describe disputes that did not necessarily pass through the CFPB, and many homeowners with a contract in progress have not reached a payoff. Three of the 15 were filed in 2026 and are classified as HELOC sub-product (Payment process; Escrow, taxes, or insurance; Foreclosure), so some homeowners and the CFPB are classifying the agreement as a home equity loan. The company's public responses were “Company disputes the facts presented in the complaint” in 7 cases and “Company believes it acted appropriately as authorized by contract or law” in 5.

Licensing and regulators

The class complaint quotes Unison's own license page as saying “Equity sharing agreements issued by Unison Agreement Corp. are not offered under mortgage lending licenses” and “Where offered, equity sharing agreements are not currently required to be licensed.” The same complaint says Unison operates in thirty states and Washington D.C. A third-party review lists a company NMLS number (2574289), which we could not check because NMLS Consumer Access blocked our request. We found no state regulator order against Unison in the documents we read, and we did not search every state; the CFPB's January 2025 report and the state laws are in our category page. Whether a state treats a home equity agreement as a loan is the question the lawsuits ask.

The court record

Cases involving Unison (as of November 11, 2026)

CaseFiled or decidedWhat it isStatus as we know it
Homeowners v. Unison Agreement Corp., Ninth Circuit No. 23-2835 (from W.D. Wash. No. 2:22-cv-01859)Class complaint December 2022; memorandum August 7, 2025Washington Consumer Protection Act claims; the panel reversed the dismissal and held that the agreement, as pleaded, gave rise to a credit obligation under Washington's reverse mortgage statuteUnpublished memorandum, not precedent. HousingWire reports a settlement in October 2025; we did not retrieve the docket
National Association of Consumer Advocates v. Unison, D.C. Superior CourtFebruary 11, 2026D.C. Consumer Protection Procedures Act; alleges unlicensed mortgage lending and deceptive “no debt” marketingPer AARP's release; we did not retrieve the docket
A homeowner v. Unison, U.S. District Court for the District of ColoradoApril 6, 2026Class action; alleges deceptive marketing; plaintiffs say they were advanced just over $87,000 and Unison estimated up to $278,618 to end the contract as of March 31, 2026Per HousingWire; docket not retrieved
Unison Agreement Contract Cases, JCCP No. 5432, San Francisco Superior CourtConsolidated amended complaint May 22, 2026Claims under California's unfair competition law, usury, elder financial abuse, quiet title, declaratory relief and unjust enrichmentPending as of the complaint; we did not retrieve the docket

In that case the Ninth Circuit wrote that, “given the details of the particular structure of this overall arrangement, which includes a formal option as one component but effectively creates the substance of a shared-appreciation reverse mortgage,” the agreement “sufficiently gave rise to” a credit obligation under the Washington statute. On marketing, the panel concluded the Olsons “adequately alleged that the statement that ‘no interest’ was involved is deceptive,” and found no pleaded facts to support the claim that “no monthly payments” was deceptive. These are the court's reading of a complaint's allegations at the motion to dismiss stage, not a finding about every Unison contract, and Unison's position is that the product is an option and not a loan. A settlement is not an admission.

SEC filings: the fund and six securitizations

Unison's capital shows up in two kinds of SEC filing. Form D is the notice of a private fund offering. Unison Midgard Fund LP (CIK 1772345; general partner Odin Midgard Fund General Partner LLC; manager Unison Investment Management, LLC, 4 Embarcadero Center, San Francisco) filed its first Form D on April 9, 2019 with a $300,000,000 offering and a $5,000,000 minimum, and has amended it every year since.

Unison Midgard Fund LP, Form D and amendments (SEC EDGAR)

FiledFormTotal soldInvestors
April 9, 2019D$300,000,0003
March 26, 2020D/A$300,000,0003
March 25, 2021D/A$337,753,2177
March 25, 2022D/A$370,696,1599
March 27, 2023D/A$449,449,3769
March 26, 2024D/A$547,918,0889
April 7, 2025D/A$547,918,0889
July 3, 2025D/A$547,918,0889
June 30, 2026D/A$593,918,08810

The latest amendment shows an offering amount of “Indefinite,” a $5,000,000 minimum and the exemptions Rule 506(b) and Investment Company Act sections 3(c)(5), 3(c)(6) and, since 2023, 3(c)(7). Total sold rose $46,000,000 between July 2025 and June 2026 (our arithmetic). A second vehicle, Unison Midgard REIT LLC (CIK 1798177), filed a Form D on December 30, 2019 reporting $125,000 sold to 125 investors with a $1,000 minimum. A Form D does not say how much of the money went into homeowner agreements.

Form ABS-15G carries the findings of third-party due diligence reviewers on securitized pools. Unison's two depositors, Unison Midgard Fund Depositor LLC (CIK 1990628) and Odin New Horizon Depositor LLC (CIK 2017322), filed six reports:

Six securitization diligence reports (SEC EDGAR)

FiledDealContracts reviewedPool contextOverall grades
October 13, 2023Unison Trust 2023-23081,023 investments; sample $27,603,611294 grade 1, 9 grade 2, 5 grade 3
May 16, 2024Unison Trust 2024-12963,677 investments at initial review1,081 grade 1, 20 grade 2, 3 grade 4 (of 1,104 in the prior review)
May 21, 2025Unison Trust 2025-134530% sample target330 grade 1, 10 grade 2, 4 grade 3, 1 grade 4
November 13, 2025UNSN 2025-2257854-loan population238 grade 1, 9 grade 2, 6 grade 3, 4 grade 4
February 2, 2026UNSN 2026-1315854-loan population298 grade 1, 9 grade 2, 8 grade 3
June 10, 2026UNSN 2026-23561,294-loan data tape354 grade 1, 1 grade 2, 1 grade 3

The reviewers checked each file against Unison's own guidelines, not against consumer-protection law; the 2026-2 narrative lists the guideline items it tested (maximum investment size, maximum Investor Percentage, minimum FICO, residency, lien and title restrictions) and excludes others. The Investor Percentage column in the 2026-2 exhibit (our arithmetic) has 356 contracts, a minimum of 20.00%, a median of 68.37%, a mean of 62.07% and a maximum of 70.00%; 169 are at exactly 70.00% and 276 at 60.00% or more. The pool mixes contracts from different years, which is why it contains 70% shares that the 60% maximum of June 2023 would no longer allow.

What a reader can do with this

  1. Ask for the dollar payoff at three home values and three dates in writing. The formula's inputs (Investor Percentage, Original Agreed Value, deferred maintenance adjustment) are in the contract; the payoff is a number Unison can calculate at signing.
  2. Check the starting point. An Original Agreed Value at 95% of the appraisal costs 20% of the advance even if the home does not move (our arithmetic at 4x).
  3. Read the exit clauses before the percentage. The Ninth Circuit memorandum describes a Special Termination Price after year 3 and a sale or death trigger; a contract that ends only by selling or paying is a different obligation from a HELOC.
  4. Check your state and the case list. Unison says it is not licensed as a mortgage lender where it offers the agreement; four suits ask whether that is right. Check whether your state has a home equity contract law (see our category page).
  5. Price the alternatives with the same home. A HELOC, a cash-out refinance or, from age 62, a reverse mortgage each have their own rules; compare total dollars at the same dates.

More on home equity contracts, read from the same kind of primary records: Splitero, Point, Unlock, Hometap, Truehold (sale-leaseback) and all five companies side by side.

FAQ

This is analysis of public documents, not investment, legal or tax advice. Sources: CFPB Consumer Complaint Database, company “Real Estate Equity Exchange, Inc. d/b/a Unison” (pulled November 11, 2026); SEC EDGAR Forms D of Unison Midgard Fund LP (CIK 1772345) and Unison Midgard REIT LLC (CIK 1798177) and Forms ABS-15G of Unison Midgard Fund Depositor LLC (CIK 1990628, accessions 0001104659-23-109042, 0001104659-25-051389, 0001104659-25-111283, 0001104659-26-009168, 0001104659-26-072243) and Odin New Horizon Depositor LLC (CIK 2017322, 0001104659-24-062496); Homeowners v. Unison Agreement Corp., No. 23-2835 (9th Cir. Aug. 7, 2025); Consolidated Amended Class Action Complaint, Unison Agreement Contract Cases, JCCP No. 5432 (May 22, 2026); AARP press release of February 11, 2026; HousingWire reporting on the Colorado class action; Finder review (updated September 21, 2026); Unison home page (Internet Archive capture of October 1, 2026).

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