ETHICS ADVISORY OPINION 2009-2 Lead Generation State Licensing Requirements and Ethical Advertising 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 2009-2 (Lead Generation State Licensing Requirements and Ethical Advertising). Introduction. This Ethics Advisory Opinion 2009-2 (Lead Generation State Licensing Requirements and Ethical Advertising) serves as a reminder to NRMLA Members that reverse mortgage lead generation services generally are considered to be licensable activity in many states, and that, accordingly, NRMLA Members engaged in providing lead generation services in such states, without also being appropriately licensed to do so, may also violate express provisions of the NRMLA Code of Ethics. Under a “typical” lead generation service arrangement of the type referred to in this Ethics Advisory Opinion, a company (“Lead Generation Provider”) assists reverse mortgage brokers, correspondents, lenders, or others in identifying consumers who may be considering or interested in a reverse mortgage loan for themselves or for others. The Lead Generation Provider may primarily provide information about reverse mortgage loans to the consumer; may not directly be involved in the reverse mortgage loan application process for the consumer; or may not originate reverse mortgage loans. However, the Lead Generation Provider also directly or indirectly solicits such consumers (generally through its website, or through other media or outreach initiatives) to provide 21
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