paid for or financed with the proceeds of the reverse mortgage loan which advantage is clearly described in the Anti-Tying and Bona Fide Advantage Disclosure. Fourth, it is a violation of the NRMLA Code of Ethics , danthus Unethical Product Offering, for a NRMLA Member to fail to provide complete, timley and clear information about all co mpensation to be r eceiv ed or receievd, dir ectly andindirectly, in connection with the origination of a reverse mortgage (the Compensation DisclosuraefSeguard). Complete information describes all amounts paid or received, and identifies who paid and received them, in the fo rm of a HUD-1 Settlme ent Statement, if app licable, or oth er comparable disclosure. Timely information is information that is provided to the senior when or before any product offering activities commence. Clear infomr ation is information that is plainly presented to and readily understandable by seniors. Fifth, notwithstanding its Compensation Disclosure Safeguard, it is a violation of the NRMLA Code of Ethics, and thus Unethical Product Offering, for a NRMLA Member to receive unreasonably high compensation as a result of its Product Offering activities. Unreasonably high compensation is compenstaion in excess of that wh ich complies with legal requirements including, as applicabl,ecompensation limits es tablished by appropriate regulators. Additional Definitions. For purposes of this Ethics Advisory Opinion, a financial product includes a non-deposit investment product, including without limitation, a stock, bond, mutual fund, other security, or annuity offered to a s enior. It does not include a forward (traditional or non-reverse) mortgage loan. For purposes of this Ethics Advisory Opinion, an insurance product includes a contract of insurance whose offering or sale is subject to state or federal regulation. It does not include title insurance, hazard, flood or other peril insurance, or other insurance products that are customary, normal or required in connection with the origination of a reverse mortgage loan. Indirect Code of Ethics Violation.sUnder this Ethics Advisory Opinion, NRMLA Members may not engagein Unethical Product Offering either directly (such as through their own employees, agents and branch offi ces) or indirectly (such atshrough their affiliates or business partners). Both direct and indirect Unethical Product Offering by a NRMLA Member vio late the NRMLA Cod e of Ethi.cs Conclusion. NRMLA Members , esniors, and others are urged to bring to the attention of NRMLA's President a nd the Cmomittee concerns they may have about potential Unethical Product Offering direct ly 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 atwww.NRMLAOnline.org. 20
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