“We now make explicit what we have held in unpublished, nonprecedential opinions. HUD regulations govern the relationship between the reverse-mortgage lender and HUD as insurer of the loan. HUD regulations do not give the borrower a private cause of action unless the regulations are expressly incorporated into the lender-borrower agreement.” Johnson v. World Alliance Financial, No. 15-50881 (July 18, 2016).
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