COMBINED-Code of Ethics and Advisory Opinions 02132024

1400 16th Street, NW Suite 420 Washington, DC 20036 Tel. 202.939.1760 Fax. 202.265.4435 Ethics Advisory Opinion 2011‐01 Wholesale Lenders, TPOs and Ethical Advertising January 18, 2011 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). On October 15, 2010, through Ethics Advisory Opinion 2010‐2 (Additional Ethical Advertising Practice Requirements), the Committee published additional and detailed guidance for NRMLA Members in the ethical advertising area. Each of these NRMLA Ethics Advisory Opinions are published and may be found on the NRMLA website at NRMLAOnline.org. 41

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