COMBINED-Code of Ethics and Advisory Opinions 02132024

NRMLA Ethics Advisory Opinion 2018-1 Re-Affirming the Code of Ethics’ Consumer Bona Fide Advantage Requirement June 29, 2018 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 termination of NRMLA Membership. The Committee also interprets the Code of Ethics. This Ethics Advisory Opinion 2018-1 (Re-Affirming the Code of Ethics’ Bona Fide Advantage Requirement) is such an interpretation of the Code of Ethics. In the course of the last decade, the Committee has issued almost twenty Ethics Advisory Opinions addressing issues arising under the Code of Ethics as diverse as Advertising (its first such opinion in 2008), Offers of Other Financial and Insurance Products, Lead Generation, Consumer Freedom of Choice, HECM-TO-HECM Refinances, and Planned HECM Loan Prepayments (its most recent such opinion in 2016). A common and central element in all of the Committee’s Opinions is the importance under Rule 107 of the Code of Ethics of NRMLA Members providing a “bona fide advantage” to consumers through the range of programs and products NRMLA Members describe and offer to consumers. NRMLA Members are required, under the express Values of the Code of Ethics, to act with “honor and integrity” for the benefit of “the seniors whose interests they serve.” They only do so if they provide such a bona fide advantage to such consumers. 77

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