COMBINED-Code of Ethics and Advisory Opinions 02132024

50 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. 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. 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. 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 senior 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. 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. It is also 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. The Committee has always intended that this list and description of the “dirty dozen” Unethical Advertising practices be considered by NRMLA Members to be simply illustrative of the requirements of the Code of Ethics, and not exhaustive. Thus, and for example, by including on this list the false or misleading advertising or marketing of reverse mortgages as “no cost” (see above), the Committee similarly intends to bar the similarly misleading advertising or marketing of them as “no fee” or “no expense.” In this respect, the Committee also is underscoring many of these same points made more recently by the Consumer Financial Protection Bureau, in its June 28, 2012 Report to the Congress on Reverse Mortgages, and reflected in NRMLA’s Borrow with Confidence Program and in the accompanying Pledge to Consumers that every NRMLA Member also is bound to honor as a condition of its continuing NRMLA membership.

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