Accordingly, it is also a violation of the NRMLA Code of Ethics for a NRMLA Member, directly or indirectly, to state or imply in its advertising or marketing to seniors or others that reverse mortgage loans either are "no cost" loans or "require no payments," or that seniors need not repay a reverse mortgage "during their lifetime" or that a senior "cannot lose" or that there is "no risk" to a senior's home with a reverse mortgage loan, at least without also explaining, in an equally prominent and conspicuous manner in such advertising or marketing, that Reverse Mortgage loans do require seniors to make certain specified payments and meet other specified obligations. Use of Celebrities NRMLA Ethics Advisory Opinion 2008‐1 already provides that it is a violation of the NRMLA Code of Ethics for a NRMLA Member to provide or arrange for a testimonial or endorsement or infomercial that fails clearly to disclose the nature of the relationship (including, if applicable, that a payment has been made as part of the relationship) between the NRMLA Member and the person or entity providing the testimonial or endorsement or infomercial. It also has been reported to NRMLA that some reverse mortgage lenders also are using celebrity images either without the celebrity’s permission or without attribution that the celebrity is paid to appear in the advertising piece on behalf of the lender, in a manner that may mislead, or be unfair or deceptive to seniors, and that also may violate applicable federal and state law requirements as further described in the Appendix that follows. Accordingly, it is also a violation of the NRMLA Code of Ethics for a NRMLA Member, directly or indirectly, to use a celebrity's image or likeness without that person’s express, written and documented permission, or to provide celebrity endorsements that do not reflect the honest opinions, findings, beliefs, or experiences of the endorsers. Further, an endorsement may not convey any express or implied representation that would be unfair, misleading or deceptive if made directly by the NRMLA Member. Pre‐Approved or Pre‐Qualified Loans Stating that a borrower is pre‐approved for a reverse mortgage without fully and clearly disclosing qualification conditions and other criteria can be misleading. (In addition, If marketers have information on seniors that does indicate that the seniors may be qualified for a reverse mortgage, and such information was received from a consumer reporting agency, such offers also may have to comply with the firm offer of credit rules under the federal Fair Credit Reporting Act and FTC regulations, if it is possible to do so, as further described in the Appendix that follows.) Accordingly, it is also a violation of the NRMLA Code of Ethics for a NRMLA Member, directly or indirectly, to state or imply in its advertising or marketing to seniors or others that an applicant or borrower is "pre‐approved" or "pre‐qualified" for a reverse mortgage loan without also fully and clearly disclosing approval or qualification conditions or other criteria that apply. 31
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