The second part of the Committee’s Inside Referral Option involves the decisions the Committee itself may make when it encounters Unethical Advertising by either NRMLA Members or non‐Members. In such situations, in addition or as an alternative to its options of imposing Membership Sanctions, Naming the Respondent, and exercising its Outside Referral Option (as described above), the Committee, at its option, also may describe to Council Members such particular Unethical Advertising practices, including with such descriptions examples of the text and substance of those practices, advertising and marketing materials, but in each case having the NRMLA staff also suitably redact such materials to remove the identity (name or other identifying characteristics) of the company or person associated with such materials. Upon receipt of such redacted descriptions, Council Members have agreed to undertake appropriate and reasonable efforts to determine, if possible, if any of the third parties (including TPOs) with which they work is engaging or may have engaged in the particular Unethical Advertising practices described by the Committee, and, if so, then to take appropriate and reasonable action in response thereto as may be permitted under that Council Member's agreement with such third party. The Committee, NRMLA, and the members of the NRMLA Wholesale Lenders Council, have concluded that adding this Inside Referral Option can have a material and positive impact upon their shared goal of eliminating Unethical Advertising, for the benefit of all industry members who engage only in Ethical Advertising practices and of the seniors whose interests they are pledged to and do serve. NRMLA Members, seniors, and others are urged to bring to the attention of NRMLA’s President and the Committee concerns they may have about potential Unethical Advertising directly or indirectly by NRMLA Members, for consideration and action by President and Committee in accordance with the procedures described in the Code of Ethics. Contact information for NRMLA may be found at its website at NRMLAOnline.org. 44
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