The Unlock Technologies lawsuit was a 2024 case in which New Jersey homeowner Angela Roberts alleged that the company’s home equity agreement was in substance a residential mortgage loan subject to the federal Truth in Lending Act, not the investment product Unlock marketed it as. The case settled in February 2026 on undisclosed terms, leaving the underlying legal question unresolved in that courtroom even as similar fights continue elsewhere.
What Roberts Alleged
Roberts filed suit on January 11, 2024, in the U.S. District Court for the District of New Jersey against Unlock Partnership Solutions AOI, Inc. and ClearEdge Title Inc. The case was docketed as 1:24-cv-1374-CPO-AMD.
Her central claim was straightforward: the “home equity contract” she signed with Unlock was a loan, and Unlock had failed to make the disclosures federal law requires of mortgage lenders. If the court agreed the product was a residential mortgage loan under the Truth in Lending Act, Roberts’s claims carried a three-year statute of limitations rather than the standard one-year window. That mattered directly to her case, because her contract dated to November 2021 and her complaint was filed more than two years later.
The Contract at the Center of the Case
Unlock Technologies, based in Tempe, Arizona, sells what it calls a Home Equity Agreement. A homeowner receives a lump-sum cash payment up front in exchange for a share of the home’s future value, with no monthly payments.
Roberts signed her agreement on November 13, 2021. Unlock paid her roughly 44% of her home’s value as a lump sum. In return, she agreed to repay Unlock either 70% of the home’s value or the original payment plus 18% annual interest, whichever applied, with the repayment coming due on a “settlement event” such as a sale, or at the end of a ten-year term. Unlock secured the arrangement with a lien on the home.
Why the “Loan” Label Drove the Case
The Truth in Lending Act applies to extensions of “credit,” which it defines as the right granted by a creditor to a debtor to defer payment of a debt. Roberts’s position was that she received money, took on a repayment obligation, and had that obligation deferred for up to ten years against a lien on her home. That, she argued, is credit, whatever Unlock chose to call it.
Unlock disagreed. The company moved to dismiss the case and separately sought to compel arbitration. Much of 2024 was spent on jurisdictional and procedural questions, including whether the TILA statute of limitations barred Roberts’s claims. ClearEdge Title, which had handled aspects of the closing, filed its own answer and crossclaims.
The CFPB Brief That Didn’t Last
On January 15, 2025, the Consumer Financial Protection Bureau filed an amicus brief supporting Roberts’s reading of the law. The Bureau argued that Unlock’s product fit TILA’s definition of credit and that the company did not bear the kind of genuine investment risk needed to qualify for Regulation Z’s “investment plan” exception. The CFPB’s point on risk was arithmetic: because Unlock paid 44% of the home’s value and stood to collect 70%, the company could remain profitable even if the home lost as much as 39% of its value. Letting companies claim the investment exception on those terms, the Bureau wrote, would create a “roadmap for evasion” of federal lending laws.
The brief was filed five days before the inauguration of President Donald Trump. On February 19, 2025, under new leadership, the CFPB moved to withdraw it, saying the original filing had not followed proper Administrative Procedure Act processes, lacked a required deference analysis, and could create “unfair regulatory surprise.” The agency said it needed to review the issue further and might take it up through formal rulemaking.
Unlock did not oppose the withdrawal. Roberts objected, arguing that striking the brief from the record would violate First Amendment principles of access to judicial records. The court granted the motion and struck the brief.
How the Case Ended
Roberts filed a notice of settlement on February 16, 2026. The next day, Magistrate Judge Ann Marie Donio administratively terminated the case for 60 days to let the parties finalize the deal. A stipulation of dismissal signed by Roberts, Unlock, and ClearEdge Title was filed on February 17, 2026, formally ending the litigation. The financial terms were not disclosed in the public filings.
Because the case ended by private settlement, the court never ruled on whether Unlock’s Home Equity Agreement is a loan under TILA. That question stayed open for Unlock and for the broader home equity investment industry.
What This Means for Other Unlock Customers
The settlement resolved Roberts’s individual claims only. It was not a class action, and it set no precedent other customers can point to. A homeowner with a similar Unlock contract who believes TILA applies would have to bring a separate case and litigate the same threshold question Roberts never got answered.
Rulings from other courts, however, have begun to accumulate on the consumer side of that question, though none involve Unlock directly. In August 2025, the Ninth Circuit held in Olson v. Unison Agreement Corp. that a competing company’s home equity investment product constitutes “credit” under the plain meaning of the word, reversing a dismissal of a class action and describing the arrangement as effectively a shared-appreciation reverse mortgage. A Massachusetts court denied Hometap’s motion to dismiss a state enforcement action the same month, finding its product is a loan because there is “no substantial risk” the company will lose its principal. An Arizona court refused in December 2025 to enforce an arbitration clause in a Point Digital Finance contract, concluding that TILA’s prohibition on mandatory arbitration in mortgage contracts applied.
States have also moved. Connecticut classified shared appreciation agreements as mortgage loans in legislation effective October 2025. Maryland regulations effective November 2024 require home equity investment providers to obtain mortgage lender licenses and meet disclosure and ability-to-repay standards. Illinois amended its Residential Mortgage License Act effective January 1, 2025, to cover shared appreciation agreements, with detailed implementing rules proposed in August 2025. Maine’s requirements have effectively kept the product out of the state entirely.
Unlock’s Position
Unlock has consistently rejected the loan characterization. CEO Jim Riccitelli has said it is “absolutely accurate” to describe the company’s agreements as non-interest-based and has argued that applying existing mortgage rules reflects a “mismatch” with how the product actually works, because the cost is not fixed until the agreement settles. He has cited internal data showing 66% of the company’s funded customers could have qualified for a traditional mortgage but chose a Home Equity Agreement to avoid monthly payments. Unlock, along with Hometap and Point Digital Finance, formed the Coalition for Home Equity Partnership in 2024 to push for what the industry calls purpose-built regulation tailored to shared equity products. The member companies have said they have never initiated a foreclosure.