COMBINED-Code of Ethics and Advisory Opinions 02132024

"Stimulus" Money; Call to Action, Sense of Urgency References to federal legislation providing more money for seniors for reverse mortgage loans typically are misleading. President Obama signed into law the American Recovery and Reinvestment Act (the "Stimulus Act") on February 17, 2009, over a year and half ago, increasing on an interim basis the HECM Maximum Claim Amount to $625,500. In addition to that action not being "recent," it also did not provide more or additional federal monies for seniors. When such inaccurate or unknown (or speculative ) information (such as that HUD or the Congress may or will "soon" reduce available loan proceeds or increase loan costs) is coupled with a "sense of urgency" or "call to action" on the part of those they are aimed at, lest they "miss out" on such a limited "opportunity," such advertising clearly may be misleading and deceptive, as also 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 “recent” federal legislation or HUD action provides more money for seniors, if such legislation or action, if any, is not recent, or if such funds have not been appropriated for seniors, especially if coupled with a sense of urgency or call to action stating or implying that if the senior does not promptly respond, he or she may or will lose or miss out on this or related “limited” opportunities. Simulated Checks and Currency Applicable law generally prohibits or limits the use of simulated currency and simulated checks, money orders, vouchers, and the like, in connection with consumer loan or mortgage marketing. This can also be construed as unfair and deceptive advertising, as 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 include as part of its advertising or marketing to seniors or others, simulated checks or currency. Use of HUD Logo Federal law prohibits the use, under all but very narrowly circumscribed circumstances, of the HUD logo or other references to HUD or the FHA in advertisements by reverse mortgage lenders among others, as described more fully below. Accordingly, it is a violation of the NRMLA Code of Ethics for a NRMLA Member, directly or indirectly, to use the names or logos of the U. S. Department of Housing and Urban Development ("HUD") or Federal Housing Administration ("FHA"), or names or logos confusingly similar in appearance, in its advertising or marketing of reverse mortgages to seniors or others, except as otherwise expressly may be permitted under applicable law. Additional details and references are described in the Appendix to this Ethics Advisory Opinion 2010‐1, that follows. 32

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