CBPLA supports useful, respectful conversations within the private lending community. Members and participants are expected to provide accurate information, respect privacy and behave professionally in directory interactions, events and other CBPLA activities.
- Respectful participation: Do not harass, discriminate, impersonate others or publish misleading information.
- Privacy: Do not publish another participant's private contact information or use directory access to collect contact lists or send unsolicited bulk messages.
- Professional claims: Describe your role, credentials and services accurately. Do not claim that membership is a license, accreditation or CBPLA endorsement.
- Competition compliance: Do not use CBPLA activities to coordinate rates, fees, customers, territories, bids or other competitive conduct. Moderators may stop an inappropriate discussion.
- Reports: Contact info@cbpla.com to report a concern. Include relevant context without sending unnecessary confidential information.
- Administration: CBPLA may review reported concerns and restrict or remove inappropriate directory content or participation under the applicable membership and event terms.
Full Code of Ethics and Professional Conduct
This Code of Ethics and Professional Conduct (this “Code”) sets out the standards CBPLA expects of every Member and named representative. Compliance with this Code is a condition of membership, as set out in the Membership Terms and Conditions and acknowledged in the Membership Application. A Member is responsible for ensuring that its representatives participating under its membership are informed of this Code.
1. Purpose and application
This Code applies to every Member and named representative in all activities conducted as, or in connection with being, a CBPLA Member — including use of the CBPLA name, logo, or directory listing; participation in committees, councils, roundtables, webinars, and events; and interactions with other Members, borrowers, and counterparties introduced through CBPLA. It is not a substitute for, and does not override, applicable law, licensing requirements, or a Member's own professional or regulatory obligations.
2. Honesty and professionalism
Members are expected to act honestly, ethically, and professionally in all dealings connected with CBPLA, and to communicate accurately and transparently with borrowers, counterparties, other Members, and CBPLA itself. Members must not make false, misleading, or exaggerated representations about their licensing status, credentials, services, track record, or affiliation with CBPLA.
3. Compliance with law
Members must comply with all applicable Canadian and U.S. federal, state, and provincial laws, regulations, and licensing requirements relevant to their business activities, including those governing lending, mortgage brokering, securities, consumer protection, anti-money laundering, and privacy. Membership in CBPLA is not a substitute for, and does not satisfy, any licensing or regulatory requirement in any jurisdiction.
4. Fair dealing
Members must treat borrowers, counterparties, and other Members fairly and in good faith, including in the negotiation, documentation, and administration of loans and referrals arranged through or connected to CBPLA relationships. Members must not use a CBPLA introduction or the CBPLA name to pressure a counterparty into an unfair or non-transparent arrangement.
5. Conflicts of interest
Members must disclose and appropriately manage conflicts of interest that arise in connection with CBPLA activities — for example, a referral fee arrangement, a personal or corporate relationship with a counterparty, or a competing role that could reasonably affect a Member's judgment or a counterparty's decision-making. Where a conflict cannot be appropriately managed, the Member should decline to proceed or fully disclose the conflict to all affected parties in advance.
6. Confidentiality
Members must protect confidential, proprietary, and personal information they obtain through CBPLA — including information from the member directory, the Cross-Border Connection Desk, committee work, or other Members — and must use it only for the legitimate purpose for which it was shared. This obligation continues after a Member's participation in a particular activity or committee ends.
7. Referrals and compensation
Members must not engage in unlawful referral fee arrangements, kickbacks, or solicitation practices, and must ensure that any compensation arrangement connected to a CBPLA introduction complies with applicable law and any applicable licensing body's rules on referral fees and compensation disclosure.
8. Due diligence
Members are expected to conduct reasonable due diligence on transactions and counterparties they engage with in connection with CBPLA relationships, consistent with prudent industry practice and applicable law. CBPLA does not perform due diligence on Members' behalf and does not vouch for the accuracy of information a Member provides to another Member.
9. Integrity and financial crime
Members must not engage in fraud, financial crime, money laundering, or material misrepresentation in connection with any transaction, disclosure, or communication related to CBPLA. A Member must promptly notify CBPLA of any material change affecting its regulatory standing, licensing status, or eligibility for membership, as described in the Membership Terms and Conditions.
10. Respectful conduct
Members and their representatives must treat other Members, CBPLA staff, committee participants, and event attendees with courtesy and respect. Harassment, discrimination, or abusive conduct in any CBPLA setting — including events, committees, councils, the member portal, or online community spaces — will not be tolerated and may result in suspension or termination of membership.
11. Use of the cbpla name and brand
Members must use the CBPLA name, logo, and any Member or Founding Member designation only as permitted under the Membership Terms and Conditions, and must not use CBPLA branding in a way that implies certification, endorsement, or approval of a transaction, counterparty, or opportunity by CBPLA.
12. Cooperation with cbpla processes
Members must cooperate in good faith with reasonable CBPLA ethics, membership, and directory-review processes, including responding to inquiries about a disclosed regulatory matter or a complaint raised by another Member or a borrower.
13. Protecting the industry's reputation
Members must avoid conduct that could materially damage the reputation of CBPLA or the cross-border private lending industry more broadly, recognizing that Members' conduct reflects on the Association and on other Members who rely on CBPLA's name and network in good faith.
14. Reporting concerns
1. A Member, representative, or third party who believes another Member has violated this Code may report the concern to CBPLA in writing, with as much detail as reasonably available.
2. CBPLA will review reported concerns in good faith and may request additional information from the parties involved. Reports are handled as confidentially as reasonably possible, consistent with the need to investigate and, where appropriate, take action.
3. A Member must not retaliate against another Member, representative, or individual for raising a good-faith concern under this Code.
15. Enforcement
A violation of this Code is a violation of the Membership Terms and Conditions and may result in a warning, mandatory corrective action, replacement of a named representative, suspension, or termination of membership, in CBPLA's discretion, as described in the Membership Terms and Conditions. Disclosure of a past matter does not automatically disqualify a Member; CBPLA may consider the nature, seriousness, relevance, age, and finality of the matter and any remedial steps taken.
16. Acknowledgment
By submitting a Membership Application or maintaining active membership, a Member confirms that it has received or reviewed this Code, agrees that compliance with this Code is a condition of membership, and agrees to ensure that all representatives participating under its membership are informed of this Code.
17. Changes to this code
CBPLA may amend this Code from time to time by posting an updated version on its website or otherwise notifying Members, consistent with the amendment provisions of the Membership Terms and Conditions.
Cross-Border Private Lenders Association · Jasmine Daya & Co. serves as legal counsel to CBPLA.