An example of such Unethical Advertising includes the cross-selling of a reverse mortgage loan and an annuity by a NRMLA Member if the annuity provides for a deferred benefit unlikely to be of bona fide advantage to the consumer, or if the related commission or other compensation to the NRMLA Member is not clearly disclosed to the consumer and to the counselor. The Ethics Committee is considering a second Ethics Advisory Opinion (2008-02) (Ethical Cross-Selling of Other Products and Services) that it contemplates will provide more comprehensive guidance with respect to the marketing or advertising by a NRMLA Member, or by a NRMLA Member in tandem or concurrently with another, of a reverse mortgage loan and another product or service, including an annuity. Sixth, it is a violation of the NRMLA Code of Ethics for a NRMLA Member to market or advertise to a business partner unreasonably high compensation, even if such compensation clearly and timely is disclosed to the consumer who pays it directly or through reverse mortgage loan proceeds. An example of such Unethical Advertising includes the marketing or advertising by a NRMLA Member of a program to a potential business partner yielding “10 points or more on a reverse mortgage loan” because such a claimed yield from the origination of a reverse mortgage loan, itself, if such loan is originated by a NRMLA Member in a manner that conforms to the requirements of this Code of Ethics, is a false and misleading claim. It is anticipated that Ethics Advisory Opinion 2008-02, referenced above, will provide additional guidance about the marketing and advertising of such programs claiming such yields as a result of the cross-selling of a reverse mortgage loan and other products and services. Indirect Code of Ethics Violations. Under this Ethics Advisory Opinion 2008-01, NRMLA Members may not engage in such Unethical Advertising either directly (such as through their own employees, agents and branch offices) or indirectly (such as through their marketing or business partners, advertising agencies, or lead generation companies). Both direct and indirect Unethical Advertising by a NRMLA Member violates the Code of Ethics. Examples of indirect Unethical Advertising by NRMLA Members that violate the Code of Ethics include Unethical Advertising that benefits a NRMLA Member that is undertaken by a NRMLA Member’s branch office or loan officers or advertising or marketing business partner, or the purchasing of leads from a lead generation company that generates such leads through marketing or advertising that would be Unethical Advertising if performed by the NRMLA Member directly or itself. Conclusion. NRMLA Members routinely and overwhelmingly engage in Ethical Advertising, for the benefit of the seniors they are pledged to serve. All the more reason, then, that there is no place in NRMLA for NRMLA Members who engage in Unethical Advertising. NRMLA Members, seniors, and others are urged to bring to the attention of NRMLA’s President and the Committee concerns they may have about potential Unethical Advertising directly or indirectly by NRMLA Members, for consideration and action by President and Committee in accordance with the procedures described in the Code of Ethics. Contact information for NRMLA may be found at its website at NRMLAOnline.com. 15
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