COMBINED-Code of Ethics and Advisory Opinions 02132024

applicable legal requirements, including the HUD Interim Guidance, and, as noted above, are separate by compensation. (2) The Separate Transaction Safeguard. The NRMLA Member shall separate the offering, marketing and origination of reverse mortgages from the offering, marketing and origination of other financial and insurance products by taking reasonable steps to assure that they are distinct and separate transactions. In this Ethics Advisory Opinion, this Safeguard is referred to as the Separate Transaction Safeguard. Under the Separate Transaction Safeguard, a distinct and separate transaction may be originated by the same appropriately licensed individual complying with the HUD Interim Guidance (in contrast, accordingly, with the Separate Originator Safeguard approach described above in which, among other things, different individuals are required to originate the transactions for the different products), as long as at least seven (7) business days (or, if required by separate legislation, any longer period during which the senior may rescind the reverse mortgage loan) have expired before the senior is offered any other financial or insurance product, and disbursement of the proceeds of a reverse mortgage loan is not made di rectly to the provider of another financial insurance product or service or at or in connection with the closing of the reverse mortgage. The Committee does not intend, through its description of the Separate Originator Safeguard and the Separate Transaction Safeguard as examples of Ethical Product Offering, to limit NRMLA Members only to these approaches in providing such Safeguards. Other approaches that achieve the HERA Goals and adhere to the HUD Interim Guidance, and that are consistent with the requirements of the Code of Conduct and this Ethics Advisory Opinion, may be utilized by NRMLA Members as Product Offering Safeguards as they engage in Ethical Product Offering. Second, in addition to the Product Offering Safeguards, a NRMLA Member engaged in Ethical Product Offering also shall provide to the senior, prior to offering such other financial or insurance products, a disclosure that is signed by both the senior and by the person making such offer, that makes clear that the senior has no obligation to purchase any such financial or insurance product with the proceeds of such reverse mortgage, and that reasonably describes to the senior the bona fide advantages to the seniors of purchasing such financial or insurance product with the proceeds of such reverse mortgage if the senior chooses to do so. In this Ethics Advisory Opinion, this disclosure is referred to as the Anti-Tying and Bona Fide Advantage Disclosure Safeguard. Third, notwithstanding its Product Offering Safeguards, it is a violationof the NRMLA Code of Ethics, and thus Unethical Product Offering, for a NRMLA Member to engage in any product offering activities involving deferred fixed rate annuities with surrender charges, deferred variable rate annuities with surrender charges, deferred equity indexed annuity with surrender charges and any financial product that applies a penalty for early withdrawal or cancellation if it does not provide a bona fide advantage to such senior when it is 19

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