COMBINED-Code of Ethics and Advisory Opinions 02132024

NRMLA Members routinely and overwhelmingly engage in ethical HECM‐to‐HECM refinancing, and not in churning activities, for the benefit of the seniors they are pledged to serve. All the more reason, then, that there is no place in NRMLA for NRMLA Members who engage in impermissible HECM‐to‐HECM refinancing practices. NRMLA Members, seniors, and others are urged to bring to the attention of NRMLA's President and the Committee concerns they may have about potential violations of the NRMLA Code of Ethics, including the Anti‐Churning requirements of this Ethics Advisory Opinion, directly or indirectly by NRMLA Members, for consideration and action in accordance with the procedures described in the NRMLA Code of Ethics. A form for that purpose also may be found at the NRMLA website, at NRMLAOnline.com. 28

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