BlueHub understands the Attorney General’s Office’s (AGO) objectives regarding shared appreciation mortgages (SAM) and supports regulations that require clear and thorough disclosures for this product.
BlueHub shares the AGO’s goal of ensuring that consumers have an understanding of how a SAM works, and what the consumer is agreeing to, as evidenced by BlueHub’s existing comprehensive disclosures.
However, we believe that certain aspects of the Proposed Regulations as they are currently drafted conflict with federal law, invite regulatory violations, and present operational and programmatic impossibilities that would effectively eliminate the use of SAMs in Massachusetts that are used for foreclosure relief, which would be to the significant detriment of Massachusetts residents.
We believe that implementing regulations requiring clear and thorough SAM disclosures can be done in a way that does not conflict with federal law and that is practically feasible, and indeed several other states with strong consumer protection interests have done so.
BlueHub looks forward to working with the Attorney General’s Office to create effective and workable SAM regulations. Given the direction of the real estate market where more and more homes are being bought up by investors for rentals, it’s important that BlueHub SUN can continue helping homeowners facing foreclosure stay in their homes and build generational wealth.
Statement: Summary Judgment on BlueHub SUN Litigation
August 25th, 2025