COMBINED-Code of Ethics and Advisory Opinions 02132024

To that end, Rules 102, 103, 104, 105 and 107 of the Code of Ethics (and Rule 301 and 302 related to the Code of Ethics Value of Integrity) expressly bar direct and indirect Unethical Advertising including marketing and advertising that is false, misleading, deceptive or unfair. Rule 102 of the Code of Ethics requires that NRMLA Member compensation be reasonable in amount and be clearly and timely described to consumers. Rule 103 of the Code of Ethics states that NRMLA Members directly or indirectly offering or providing goods or services to consumers (including, for example, insurance or investment products) in conjunction with or that are related to their reverse mortgage lending activities for such consumers, shall do so only in a manner consistent with applicable law and under terms and conditions that are clearly and timely described to consumers. Rule 104 of the Code of Ethics provides that NRMLA Members shall not, directly or indirectly, solicit or communicate with consumers through false, misleading, deceptive, or unfair communications or advertisements, or in any manner inconsistent with applicable law. In such a communication or advertisement, a NRMLA Members shall not refer to a third party (e.g., HUD, FHA, the federal government, AARP) in a manner that misleadingly suggests that such communication is from such third party rather than from such NRMLA Member, and, in the case of NRMLA and AARP, unless each has agreed to be referred to in such advertisement. A communication or advertisement by or on behalf of a NRMLA Member shall clearly identify that member. Rule 105 of the Code of Ethics states that NRMLA Members shall not engage in conduct involving dishonesty, fraud, deceit or misrepresentation, or knowingly make a material false or misleading statement to consumers or others. Rule 107 of the Code of Ethics requires that NRMLA Members describe to consumers the range of programs and products offered by the Member that may provide “a bona fide advantage to such consumers.” Rule 301 of the Code of Ethics requires NRMLA Members accurately to describe both the costs and benefits of the products and services presented to consumers. Rule 302 of the Code of Ethics bars NRLMA Members from requiring, directly or indirectly, that consumers purchase other products or services in order to obtain reverse mortgage loans. Unethical Advertising Rules and Examples. These Code of Ethics Values and Rules, singly and together, support the Committee’s conclusions that the following practices constitute Unethical Advertising that violate the NRMLA Code of Ethics. First, it is a violation of the NRMLA Code of Ethics for a NRMLA Member to market or advertise its particular FHA-insured HECM loan programs as “Government Loan Programs,” or as a “Government Benefit” or as “Government Supported” or as one from or offered by a “Government Loan Division” or as “Official Business” or as “Endorsed” or “Approved” by the Government, by the Federal Government, by HUD, by the FHA, by AARP, or by NRMLA. 13

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