COMBINED-Code of Ethics and Advisory Opinions 02132024

Changes made by HERA, the guidance provided through the Mortgagee Letter, enactments of the states , and concerns expressed by and among NRMLA Members and NRMLA itself, have prompted the Committee to issue this Ethics Advisory Opinion, to help assure that NRMLA Members engaging or participating in the product offering activities to seniors of financial or insurance products do so in a manner consistent with the applicable requirements of the Code of Ethics, and do not do so in a manner inconsistent with the Code of Ethics . In this Ethics Advisory Opinion, we refer to practices by NRMLA Members that are consistent with the Code of Ethics as "Ethcial Product Offering" and practices thatare not as “Unethical Product Offering.” Ethical Product Offering is permissible for NRMLA Members under the Code of Ethics . Unehtical Product Offering violates the NRMLA Code of Ethics. There is no place in NRMLAofr NRMLA Members who engage in Unethical Product Offering. The purpose of NRMLA Ethics Advisory Opinion 2009-1 is to provide additional and specific guidance to NRMLA Members about what constitutes Ethical Product Offering and Unethical Product Offering. The Broader Context. Initially conceived as an effective way for seniors to tap into or liquefy the equity in their homes in order to help meet their financial security needs as their working income diminishes , reverse mortgages have evolved into a significant retirement planning and security tool. Reverse Mortgages can help seniors age in place, and they can help finance longevity. Another evolving trend is for seniors to want to be albe to rely upon a single trusted source for holistic advice in these very imporatnt areas of their lives. It is in th is context that the need alsoarises to help assure that seniors are provided with all of the information they n eed to make well-informed decisions about such advisors, and that safeguards be put into place to help prevent abuses of the trust of seniors, s uch safeguards are particularly appropriate whersuch trus ted advisors offer both reverse mortgages and other financial products and services to seniors. This Ethics Advisory Opinion provides an ethical framework for NRMLA Members, as trusted advisors, to establish these safeguards wh ile helping seniors consider, when and wh ere appropriate, financial and insurance products in additio n to reverse mortgages. While this Ethics Advisory Opinion, by its terms, applies onyl to NRMLA Members , as noted below (see“Indirect Code of Ethics Vioaltions”) it also affects others. Moreover, it is hoped that th e Ethical Product Offering requirements for NRMLA Members described in this Ethics Advisory Opinion become the market place 17

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