RULES INVOLVING ADVERTISING for reverse mortgages can be overwhelming, partly because numerous jurisdictions on the state and federal levels have regulations or enforce them. While companies may find it difficult to keep track of what is expected, they must do so, according to James M. Milano and Joel Schiffman, attorneys with Weiner Brodsky Kider PC in Washington, DC. “There are lots of laws from many places,” Milano says, adding that NRMLA’s “Code of Ethics & Professional Responsibility” provides sound guidance as companies seek to understand their responsibilities. During a NRMLA seminar in May titled “Advertising and Ethics,” Milano and Schiffman, whose law firm serves as outside general counsel to NRMLA, outlined additional best practices and encouraged NRMLA members to learn as much as they can about what is expected of them. One way to stay on top of regulators’ expectations is to monitor enforcement actions, a practice encouraged by the Consumer Financial Protection Bureau (CFPB), Milano says. CFPB leaders have suggested it is “compliance malpractice” not to do so, he adds. Learning From Others Regardless, Milano says, companies can learn by monitoring regulatory actions, even if it is a matter of “there but for the grace of God, go I.” Since 2015, the CFPB alone has taken more than a half dozen actions involving reverse mortgage advertising, Milano says. Advertising Rules Explained Attorneys: Companies Must Know Rules and Ethical Guidelines By Thomas A. Barstow Joel Schiffman James M. Milano 28 REVERSE MORTGAGE / SEPTEMBER–OCTOBER 2022
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