COMBINED-Code of Ethics and Advisory Opinions 02132024

and NRMLA to help stamp out Unethical Advertising practices. Its enhanced process for doing so is described in this Ethics Advisory Opinion 2011‐01: Wholesale Lenders, TPOs and Ethical Advertising. It establishes an additional remedy available to the Committee for Unethical Advertising violations of its Code of Ethics, and it is referred in this Ethics Advisory Opinion as the Committee's "Inside Referral Option." The members of the NRMLA Wholesale Lenders Council are NRMLA Lender Members that work with third party originators (TPOs) to originate reverse mortgage loans and that have agreed to and do support NRMLA and its mission though additional contributions and resources. Under the NRMLA Code of Ethics, NRMLA Members, including Council Members, may not engage, either directly or indirectly, in conduct that violates the Code. Accordingly, and for example, a NRMLA Member that retains or arranges with a third party (including a TPO) to assist in the origination or marketing of reverse mortgage loans, or in the generation of leads for reverse mortgage loans, is and will be held responsible under the NRMLA Code of Ethics for the actions of such third parties undertaken on its behalf or for its benefit that involve Unethical Advertising or other violations of the NRMLA Code of Ethics and its Ethics Advisory Opinions to the same extent as if it was the NRMLA Member itself, rather than such third party, that undertook such actions. NRMLA Members that are Council Members have agreed to go further, however, in support of this ongoing effort by NRMLA and the Committee to root out Unethical Advertising and the Committee’s Inside Referral Option for doing so. Council Members also have agreed to include, in due course, within their agreements with each TPO or other third party with which they work, a requirement that each such TPO and third party also comply with relevant provisions of the NRMLA Code of Ethics and its Ethics Advisory Opinions, whether or not such TPO or third party is, itself, a NRMLA Member. This, then, is the first part of the Committee’s Inside Referral Option for helping to root out Unethical Advertising—the adoption by members of the NRMLA Wholesale Lenders Council of the NRMLA Code of Ethics as a requirement applicable to the third parties (including TPOs) with which such Council Members work. 43

RkJQdWJsaXNoZXIy MjQ1MzY1