The borrower check is meaningfully different, and the clock issue you raised is the right thing to worry about.
When you lend against a tax lien certificate, the collateral is a legal claim on a property, not ownership of the property itself. The certificate holder has the right to collect the owed taxes plus statutory interest (the rate set by state law), and eventually the right to start a foreclosure process if the owner never pays. Your borrower owns that claim, not the property.
Sizing is harder for two reasons. First, the claim has a ceiling: the borrower can collect only the face amount of the lien plus the statutory interest rate, no more. If you lend close to that ceiling and the owner redeems early, your borrower gets paid out quickly, which is fine. If the owner never redeems, your borrower has to go through a formal foreclosure process, which varies a lot by state and can take one to three years. Your money sits locked in while that plays out.
Second, you cannot simply fall back on the property value the way you would with a deed. If the borrower defaults on your loan before the certificate resolves, you step into their position in the certificate, not into a deed. You would then need to complete the foreclosure yourself to reach the real estate. That is a procedurally specific process, and some states have strict deadlines that can extinguish the certificate if they are missed. A real estate attorney in the relevant state is the right person to map that timeline before you agree to terms.
The strategy guide's note that most liens redeem is relevant here: the more likely exit is a cash payoff within the redemption window, which may actually simplify your underwriting compared to the worst-case scenario.
What state is the certificate in? Redemption periods and foreclosure procedures differ enough that the state would change which risks matter most.