For Commercial Capital Advisors

Membership in the Association is a privilege that carries with it the responsibility to uphold the highest standards of professionalism, integrity, and client advocacy. By accepting membership, every advisor agrees to abide by this Code of Ethics and to represent the Association, the industry, and their clients with honor and transparency.

1. Commitment to Professional Integrity
   • Conduct all business with honesty, fairness, and transparency.
   • Avoid any deceptive, misleading, or unethical practices in client interactions, lender relationships, or marketing.
   • Represent yourself exclusively as a commercial capital advisor. The terms “loan broker,” “mortgage broker,” or any unrelated designation are not permitted, as they misrepresent the advisory nature of the role.
2. Client-First Advisory Standards
   • Prioritize the client’s best interest above personal gain in every engagement.
   • Provide clear, accurate information about available capital options, including potential risks, costs, and obligations.
   • Maintain confidentiality of client information and protect sensitive data in accordance with applicable privacy and security regulations.
   • Offer guidance that is informed, impartial, and based on the client’s true financial needs and objectives.
3. Ethical Conduct in Capital Sourcing
   • Maintain complete transparency with lenders and capital partners by providing accurate and timely information.
   • Submit only legitimate, verifiable applications and documentation for consideration.
   • Never engage in misrepresentation, fabrication, or omission of material facts to influence an approval or decision.
   • Decline participation in any transaction that involves fraud, predatory practices, or any activity that could harm the client, the lender, or the reputation of the Association.
4. Professional Growth and Education
   • Commit to ongoing professional development to remain informed about industry trends, capital structures, regulatory changes, and best practices.
   • Share knowledge and resources with peers in the Association to elevate the professionalism and expertise of the community as a whole.
5. Respect and Collaboration
   • Treat clients, lenders, partners, and fellow advisors with respect, courtesy, and professionalism.
   • Engage in collaborative relationships that foster trust and mutual success.
   • Avoid disparaging other members, lenders, or industry participants.
6. Compliance with Laws and Regulations
   • Operate in full compliance with all applicable federal, state, and local laws and regulations.
   • Adhere to the Association’s standards and policies at all times.
   • Report unethical or illegal behavior to the Association to protect the integrity of the membership body.
7. Responsibility to the Industry and the Association
   • Act as a steward of the Association’s reputation by conducting business in a manner that reflects positively on the industry.
   • Contribute to the advancement of ethical standards and practices across the commercial capital space.
   • Abstain from any activity that undermines the credibility, mission, or vision of the Association.
8. Enforcement and Accountability

   Members acknowledge that adherence to this Code of Ethics is a condition of ongoing membership. Violations may result in disciplinary action, including but not limited to suspension or revocation of membership, as determined by the Association’s ethics committee.

Enforcement and Accountability Policy

For Commercial Capital Advisors

This policy governs the process for enforcing the Association’s Code of Ethics. It ensures that all members are held to the same standards of professionalism and integrity, while providing fair, consistent procedures for addressing concerns or violations.

1. Purpose

   The Association is committed to maintaining the integrity of its membership and the reputation of the commercial capital advisory profession. This policy provides a structured process for receiving, reviewing, and resolving complaints regarding potential violations of the Code of Ethics.

2. Reporting a Complaint
   • Complaints may be submitted by clients, lenders, other members, or members of the public.
   • Complaints must be submitted in writing through the Association’s designated reporting channel and include supporting evidence or documentation whenever possible.
   • Anonymous complaints may be reviewed at the Association’s discretion if sufficient evidence is provided.
3. Initial Review
   • Upon receipt, the Ethics Committee will conduct an initial review to determine whether the complaint falls within the scope of the Code of Ethics.
   • If the matter is outside the Association’s jurisdiction, the complainant will be notified, and the complaint will be closed.
   • If the matter is within scope, the member named in the complaint will be notified and given an opportunity to respond.
4. Investigation Process
   • The Ethics Committee will gather all relevant information, which may include interviews, document review, and communication with involved parties.
   • Members under investigation must cooperate fully and provide requested documentation or explanations in a timely manner.
   • All investigations will be handled with confidentiality to protect the privacy and reputation of all parties during the process.
5. Determination and Outcomes

   After the investigation, the Ethics Committee may take one or more of the following actions:

   • No Action – If no violation is found, the matter is closed without further action.
   • Advisory Letter – A written notice of concern may be issued when the behavior does not rise to a violation but warrants guidance.
   • Formal Warning – A written warning that the member’s actions violated the Code of Ethics, requiring corrective action to prevent future violations.
   • Suspension – Temporary loss of membership privileges for a defined period, subject to corrective conditions.
   • Revocation of Membership – Permanent termination of membership when the violation is severe or when the member fails to correct repeated misconduct.
6. Appeals
   • Members have the right to appeal disciplinary actions within 30 days of notification.
   • Appeals must be submitted in writing and must include evidence or reasoning supporting the request for reconsideration.
   • Appeals will be reviewed by an independent panel appointed by the Association’s Board.
7. Confidentiality and Records
   • All proceedings, communications, and records related to complaints and investigations will remain confidential except where disclosure is required by law or deemed necessary to protect the Association or the public.
   • Records of investigations and disciplinary actions will be maintained by the Ethics Committee for internal reference and historical documentation.
8. Integrity of the Process
   • The Association will ensure that all complaints and investigations are handled impartially and without bias.
   • Members of the Ethics Committee must recuse themselves from any case where a conflict of interest exists.
9. Public Notices
   • Only final disciplinary actions involving suspension or revocation may be publicly disclosed.
   • Notices will include the nature of the violation but will not disclose sensitive or private details unless necessary for public understanding.
10. Ongoing Accountability
    • All members agree, as a condition of membership, to comply with any corrective measures imposed by the Ethics Committee.
    • Failure to comply with directives or continued violations will result in escalation to permanent revocation of membership.

Code of Ethics
For Lender Members

Membership in the Association reflects a lender’s commitment to integrity, transparency, and a collaborative approach to serving the commercial capital advisory community. By joining, lenders agree to uphold these principles and to conduct all business with the highest standards of professionalism.

1. Commitment to Fair and Transparent Practices
   • Provide clear, accurate, and timely information regarding lending products, pricing, terms, and qualification criteria.
   • Ensure that all offers, approvals, and denials are communicated promptly and with sufficient explanation for advisors and clients to understand the decision.
   • Avoid any misleading marketing, hidden fees, or unfair practices that could harm advisors, clients, or the reputation of the Association.
2. Respect for the Advisor Relationship
   • Recognize that commercial capital advisors are independent professionals serving their clients’ best interests.
   • Never attempt to bypass, circumvent, or replace an advisor in any transaction where they facilitated or originated the relationship with the client.
   • Honor all agreements regarding compensation, referrals, and protected relationships.
3. Commitment to Clients’ Best Interests
   • Ensure that offered capital solutions are appropriate for the client’s needs and financial situation.
   • Provide clients with all material terms and obligations in a manner that allows informed decision-making.
   • Decline to participate in any transaction where the terms would knowingly harm the client or place them in unsustainable debt.
4. Compliance with Laws and Regulations
   • Operate in full compliance with applicable federal, state, and local regulations governing commercial finance, including disclosure and anti-discrimination laws.
   • Maintain proper licensing, registration, and compliance programs where required by jurisdiction or product type.
5. Collaboration and Professionalism
   • Treat all advisors, clients, and industry partners with professionalism, courtesy, and respect.
   • Respond to inquiries, applications, and funding requests in a timely manner to support efficient and ethical transactions.
   • Provide constructive feedback to advisors when applications cannot be approved, so that clients may pursue more suitable options.
6. Confidentiality and Data Security
   • Safeguard the privacy and security of client and advisor information in accordance with applicable data protection standards and best practices.
   • Use shared data solely for the purpose of fulfilling transactions and never for unauthorized solicitation or resale.
7. Contribution to Industry Standards
   • Support the advancement of ethical, sustainable practices within the commercial capital industry.
   • Provide feedback and collaborate with the Association to improve tools, processes, and education that benefit the community as a whole.
   • Report unethical or fraudulent activities observed within the market to the Association when appropriate.
8. Accountability and Enforcement
   • Acknowledge that adherence to this Code of Ethics is a condition of ongoing membership.
   • Cooperate fully with any Association inquiry or investigation into complaints or allegations of misconduct.
   • Understand that violations may result in corrective action, suspension, or removal from membership to protect the integrity of the Association.

Enforcement and Accountability Policy

For Lender Members

This policy governs how the Association enforces its Code of Ethics for lender members. It ensures that concerns are handled fairly, consistently, and with full regard for protecting the integrity of the Association, its broker members, and the clients they collectively serve.

1. Purpose

   The Association is committed to fostering a trusted environment where brokers, lenders, and clients can collaborate with confidence. This policy provides a clear, standardized process for reporting, investigating, and resolving violations of the Lender Code of Ethics.

2. Reporting a Complaint
   • Complaints may be filed by brokers, clients, other lenders, or members of the public.
   • Complaints must be submitted in writing to the Association through the designated reporting channel, including as much supporting documentation as possible.
   • Anonymous complaints may be considered if sufficient evidence is provided to warrant review.
3. Initial Review
   • The Ethics Committee will review each complaint to determine jurisdiction and scope.
   • If the complaint falls outside the scope of this policy or does not involve a Code of Ethics issue, the complainant will be notified, and the case will be closed.
   • If the complaint is valid for review, the lender will be formally notified and given the opportunity to provide a written response.
4. Investigation Process
   • The Ethics Committee will conduct an impartial investigation, which may include reviewing documents, communications, and testimony from involved parties.
   • Lenders are required to cooperate fully and promptly with all investigative requests.
   • All investigations will be handled confidentially to protect the reputation of all parties until a determination is made.
5. Determination and Outcomes

   Following the investigation, the Ethics Committee may issue one or more of the following actions:

   • No Action – When no violation is found or evidence is insufficient.
   • Advisory Notice – Non-disciplinary guidance identifying practices that may lead to future concerns if uncorrected.
   • Formal Warning – Documentation of a verified violation, requiring immediate corrective action to remain in good standing.
   • Suspension – Temporary suspension of lender membership privileges for a defined period, typically paired with mandatory remediation steps.
   • Revocation of Membership – Permanent removal from the Association in cases of serious, repeated, or uncorrected violations.
6. Appeals
   • Lenders have 30 days from the date of notice to appeal disciplinary actions.
   • Appeals must be in writing and include reasoning or evidence supporting reconsideration.
   • Appeals will be reviewed by an independent panel designated by the Board of Directors to ensure impartiality.
7. Confidentiality and Recordkeeping
   • All records, communications, and proceedings related to a complaint or investigation are confidential and may only be disclosed when legally required or necessary to protect the Association or the public.
   • Records of all investigations and actions will be maintained securely by the Ethics Committee for reference and accountability.
8. Integrity of the Process
   • Investigations and decisions will be conducted fairly and without bias.
   • Any committee member with a conflict of interest in a specific case must recuse themselves to ensure impartiality.
9. Public Disclosure
   • Final disciplinary actions involving suspension or revocation of lender membership may be publicly disclosed to protect brokers, clients, and the Association’s reputation.
   • Public notices will summarize the reason for the action but will avoid releasing confidential or unnecessary details.
10. Ongoing Accountability
    • Lenders agree to comply with all corrective actions or conditions required by the Association as part of disciplinary resolutions.
    • Failure to comply or repeated violations will result in permanent removal from membership and may bar future reapplication.