Attention also is called to Ethics Advisory Opinion 2013-4 (Ethical Considerations Affecting HECM Loan MIP Premium Decisions), published on October 17, 2013. It requires, among other things, that NRMLA Members describe to consumers, in a clear and timely manner, the amounts of the initial mortgage insurance premium (MIP) that they will owe to HUD under the Disbursement Amount Elections available to them under the HECM program, and to compare those amounts with amounts such consumers will receive as Initial Disbursements as a result of their elections--all in order to help assure that such consumers receive a "bona fide advantage" as a result of their HECM loan program and product decisions, as required under the Code of Ethics. Finally, the particular attention of NRMLA Members involved in HECM-to-HECM refinancing also is drawn to the continuing restrictions and limitations of Ethics Advisory Opinion 2013-3. In particular, and as described in Ethics Advisory Opinion 2013-3 (Ethical Refinancing of HECM Single Disbursement Lump Sum Payment Option Loans and Anti-Churning Practices), the Committee emphasized that the Code of Ethics does “not permit NRMLA Members to advise consumers, directly or indirectly, to plan to refinance HECM Single Disbursement Lump Sum Payment Option Loans into other HECM loans for such consumers within the twelve month period following the closing of such initial HECM loans, and that, as a result, and in addition, NRMLA Members may not directly or indirectly refinance or assist in the refinancing of such loans into other HECM loans within such period.” NRMLA Members routinely and overwhelmingly engage in ethical HECM‐to‐HECM refinancing, and not in churning activities, for the benefit of the seniors they are pledged to serve. All the more reason, then, that there is no place in NRMLA for NRMLA Members who engage in impermissible HECM‐to‐HECM refinancing practices. 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 violations of the NRMLA Code of Ethics, including the Anti‐Churning requirements of this Ethics Advisory Opinion, directly or indirectly by NRMLA Members, for consideration and action in accordance with the procedures described in the NRMLA Code of Ethics. A form for that purpose also may be found at the NRMLA website, at NRMLAOnline.com. 67
RkJQdWJsaXNoZXIy MjQ1MzY1