Mortgage lenders figure to be among those to benefit the most from new tax laws as citizens scramble to unlock the billions of dollars they have invested in their homes.

Under the new rules, house-rich but cash-poor citizens will be permitted to pocket $500,000 of tax-free profits from home sales-and spend the proceeds as they please. Some say they will opt to buy less expensive homes, spurring additional business for lenders.

"It's definitely creating a sense of liberation," said Sharon Rich, a financial planner in Belmont, Mass. "I've got clients who are very excited."

Over the next six months, Realtors and lenders predict a surge in houses for sale, boosting real estate commissions, appraisal fees, and mortgage loans.

"You especially have that 45-55 (age) group that may end up thinking about possibly even downsizing-moving to a smaller house," said Craig Davis, executive vice president of mortgage lending and financial services at Washington Mutual Inc., now that "they don't have to wait until they are 55."

Under the old law, homeowners 55 or older could pocket $125,000 of tax- free profits on home sales just once in their lifetimes. For all others, the only way to avoid a big tax bill on home sale gains was to roll them over into another house within two years.

"People are being forced to hold an undiversified portfolio because they have all this equity in their house," said Peter Chinloy, professor of finance and real estate, American University, Washington.

Freed of that tax incentive to buy and hold bigger homes than they may have wanted, homeowners will shift money from home equity to stocks and mutual funds over the long haul, predicted analyst Charlotte A. Chamberlain of Jefferies & Co., Los Angeles.

Thus the tax changes would intensify a shift that is already under way, Ms. Chamberlain said. In 1995, for the first time in 22 years, Americans had more money in stocks and mutual funds than in their homes, as the runaway stock market multiplied the value of their holdings while slow home price appreciation held down home equity values, according to Federal Reserve data.

The trend has accelerated since then, according to estimates by Regional Financial Associates, West Chester, Pa.

Still, for most Americans, homeownership is not just about building financial assets. It's a powerful symbol of the good life.

So many housing and financial professionals say that young and middle- aged Americans won't easily be parted from trophy homes, even if their money could be better invested elsewhere.

These experts said they expect the tax law mainly to affect the decisions of retiring Americans, who often move to smaller homes, and of homeowners moving out of high-priced states, such as California, to less expensive markets. High-end homes in these markets will lose some of their appeal, Mr. Chinloy said.

In Salt Lake City, Russell K. Booth, president of the National Association of Realtors, gave the example of a couple moving from San Francisco or Honolulu, where the median home price is more than double Salt Lake City's $147,000 average.

The new tax law "truly does give people more options" to put money in the stock market, college tuition, or a distribution to their children, said Mr. Booth, president of Mansell Commercial Real Estate Services Inc., Midvale, Utah.

In Florida, where growth has been boosted by migrants, often retirees, from other parts of the country, the new tax bill will curb the growth of the high-priced-housing market, said Randall C. Johnson, chairman of Market Street Mortgage Corp., Clearwater.

"The growth will be in the medium- and moderate-priced homes," Mr. Johnson said.

In Boston's affluent suburbs of Newton, Watertown, and Lincoln, said Ms. Rich, the financial planner, the tax relief will help many who are sitting on huge equity gains they made in the 1980s. Home prices in the area doubled from 1984 to 1986.

One clientwants to sell out and use the equity to put the kids through college, Ms. Rich said. Another, a 65-year-old retired woman, just can't afford her big home anymore.

In many cases, the freed-up money will pay off credit card debt, Ms. Rich said.

Frederick E. Flick, the Realtors association's vice president of research, said he thinks those affected by the new tax rules will be "primarily people on the upper end who are very sensitive to the investment value of their portfolio."

Homes worth more than $500,000 typically account for only 2% to 3% of resales, Mr. Flick said.

But people with far less equity will take advantage, said Gail Lyons, Boulder Real Estate Services Ltd./Realty Executives, Boulder, Colo.

Ms. Lyons has just heard from a client who wants to sell a $150,000 condo, which she left two years ago and now rents.

"It's time to sell the rental. We want to take advantage of the new income tax," Ms. Lyons reported that her client had said. The sale is expected to yield a gain of about $40,000, tax-free.

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