ETHICS ADVISORY OPINION 2009-1 Ethical Offers of Other Financial and Insurance Products and Services June 16, 2009 The Ethics and Standards Committee (the "Committee") of the National Reverse Mortgage Lenders Association ("NRMLA"), the trade association of the reverse mortgage lending industry, enforces the NRMLA Code of Ethics and Professional Responsibility (the "Code of Ethics"). All NRMLA Members are required to comply with the Code of Ethics as a condition of their continued membership in NRMLA. If the Committee determines that a NRMLA Member has not complied with the Code of Ethics, sanctions may be imposed, up to and including the termination of NRMLA Membership. Committee decisions enforcing the Code of Ethics may be made public. The Committee also interprets the Code of Ethics, and, from time to time, proposes changes to it for consideration and approval by the NRMLA Board of Directors. This is one of a series of formal Committee interpretations of the NRMLA Code of Ethics. It is Ethics Advisory Opinion 2009-1 (Ethical Offers of Other Financial and Insurance Products and Services). It replaces Ethics Advisory Opinion 2008-2, which was issued by the Committee and NRMLA on April 21, 2008, and which is hereby withdrawn. This Ethics Advisory Opinion reflects, among other things, new guidance in this area provided by the U.S. Department of Housing and Urban Development (HUD) through Mortgagee Letter 2008-24 (September 16, 2008) (the Mortgagee Letter) and related relevant provisions of the recently enacted Housing and Recovery Act of 2008 (HERA), and related enactments in California (California Civil Code 1923.2(i)) and Rhode Island (Code, Section 34-25.1-7), among others. NRMLA Ethics Advisory Opinions, and the NRMLA Code of Ethics, are published on the NRMLA website, www.NRMLAOnline.org. Introduction. This Ethics Advisory Opinion 2009-1 (Ethical Offers of Other Financial and Insurance Products and Services) addresses a very important aspect of the relationship between NRMLA Members and the seniors whose financial security interests they are pledged to serve: the manner and extent to which NRMLA Members, consistent with the applicable requirements of the Code of Ethics , may refer, recommend, originate for or offer or crosssell to, their senior reverse mortgage consumers (collectively, "product offering activities"), financial or insurance products (inc luding but not limited to annuities and as further defined below) other than reverse mortgage loans. 16
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