22 information about themselves (such as their names, addresses, contact information, property locations, ages) (collectively “Lead Information”); collects that information; and provides that information to reverse mortgage brokers, lenders, or others. Generally, but not always, Lead Generation Providers are compensated for providing Lead Information. Lead Generation Providers, and the NRMLA Lender Members who work with them, are also the subject of NRMLA Ethics Advisory Opinion 2008-1 (Ethical Advertising). The NRMLA Code of Ethics The NRMLA Code of Ethics applies to Lead Generation Providers that are NRMLA Members. The first Value that the NRMLA Code of Ethics embraces is Fairness. Fairness under the Code of Ethics requires that NRMLA Members treat seniors with “respect and dignity, and in a manner that is fair, reasonable, and as they would want to be treated.” Additional Values embraced under the Code of Ethics require Integrity, Competence, Diligence, and Professionalism. Rule 103 of the Code of Ethics states that NRMLA Members directly or indirectly offering or providing goods or services to seniors (including, for example, insurance or investment products) in conjunction with or that are related to their reverse mortgage lending activities for such seniors, shall do so only in a manner consistent with applicable law and under terms and conditions that are clearly and timely described to seniors. Rule 104 of the Code of Ethics states, in pertinent part, that NRMLA Members shall not, directly or indirectly, solicit or communicate with consumers through false or misleading or deceptive or unfair communications or advertisements or in any manner inconsistent with applicable law. Rule 401 of the Code of Ethics requires NRMLA Members to acquire and maintain the necessary and appropriate knowledge, skills and experience required to competently offer and provide their products and services in a manner consistent with this Code of Ethics and applicable law, including, as applicable, in the origination, processing, underwriting, closing and servicing of reverse mortgage loans. Rule 602 of the Code of Ethics requires NRMLA Members to neither accept nor condone actions or failures to act of other NRMLA Members that are inconsistent with this Code of Conduct. NRMLA Members knowledgeable about potential material violations of this Code of Ethics by others subject to its provisions strongly are encouraged to bring such potential violations to the attention of NRMLA in the manner described in this Code of Ethics.
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