COMBINED-Code of Ethics and Advisory Opinions 02132024

Table of Contents NRMLA Code of Ethics & Professional Responsibility………………………………………….1 ETHICS ADVISORY OPINION 2008-01: Ethical Advertising………………………………...12 Published February 28, 2008 ETHICS ADVISORY OPINION 2009-1: Ethical Offers of Other Financial and Insurance Products and Services……………………………………………………………………………16 Published June 16, 2009 ETHICS ADVISORY OPINION 2009-2: Lead Generation State Licensing Requirements and Ethical Advertising………………………………………………………………………………21 Published June 16, 2009 ETHICS ADVISORY OPINION 2010‐01: ETHICAL HECM‐TO‐HECM Refinancing and Anti- Churning Practices……………………………………………………………………………….25 Published September 30, 2010 ETHICS ADVISORY OPINION 2010‐02: Additional Ethical Advertising Practice Requirements…………………………………………………………………………………….29 Published October 15, 2010 ETHICS ADVISORY OPINION 2011-01: Wholesale Lenders, TPOs and Ethical Advertising………………………………………………………………………………41 Published January 18, 2011 ETHICS ADVISORY OPINION 2011-02: Ethical Refinancing of Reverse Mortgage Loans …………………………………………………………………………………45 Published February 24, 2011 ETHICS ADVISORY OPINION 2012-1: 2012 Update: Ethical Advertising Practice Requirements…………………………………………………………………………………….47 Published September 20, 2012 ETHICS ADVISORY OPINION 2013-1: Ethical Product Offerings………………...................54 Published April 18, 2013 ETHICS ADVISORY OPINON 2013-02: Full Draw HECM Loan Repayment Considerations…………………………………………………………………………………...56

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