COMBINED-Code of Ethics and Advisory Opinions 02132024

NRMLA ETHICS ADVISORY OPINION 2010‐02 ADDITIONAL ETHICAL ADVERTISING PRACTICE REQUIREMENTS October 15, 2010 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 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. On February 28, 2008, over two years ago, the Committee issued its first formal interpretation of the then new NRMLA Code of Ethics, Ethics Advisory Opinion 2008‐01 (Ethical Advertising). The following year, on June 16, 2009, the Committee issued a related and follow‐up interpretation, Ethics Advisory Opinion 2009‐02 (Lead Generation State Licensing Requirements and Ethical Advertising). NRMLA Ethics Advisory Opinions are published and may be found on the NRMLA website at NRMLAOnline.org. The two earlier Ethics Advisory Opinions rely on and cite to a series of Values and Rules described in the NRMLA Code of Ethics that address what Ethics Advisory Opinion 2008‐01 characterized as a very important aspect of the relationship between NRMLA Members and the seniors whose interests they are pledged to serve: the manner in which NRMLA Members make, advertise and make known to seniors the reverse mortgage loans and programs they offer to them. Ethics Advisory Opinion 2008‐01 also expressly noted the growing concern among seniors and their advocates and legislators, and among NRMLA Members and NRMLA itself, that some NRMLA Members are engaging , participating, or tolerating marketing and advertising practices that are false, misleading, deceptive or unfair‐‐referred to in that Opinion, collectively, as "Unethical Advertising." 29

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