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a. Review responses under the Third Party Vendor section of the ICQ and the text of the bank's oversight program.
b. Review the scope and frequency of completed and scheduled oversight reviews and reviews of customer complaints and their resolution. c. Review bank management's response to recommendations made during past examinations.
d. Review the third party vendor agreement and determine: -Whether it specifies that such
entities will comply with all applicable requirements, including those in the Interagency Statement.
How bank management assures itself that third party vendors comply with the terms of the agreement.
Retail Nondeposit Investment Sales
views of the ongoing prudence of
The quality of the holdings,
19. Determine how effective the bank's
The independence of compliance
• Training provided to compliance
• Automated exception reporting
•The scope, frequency, and findings
20. Determine whether results of periodic
21. If prior examination findings, compliance reports, a pattern of customer complaints, or routine oversight by bank management identifies the possibility that suitability problems may exist, determine if bank management has conducted a thorough review of all affected accounts and instituted appropriate corrective actions.
Third Party Vendors
22. Determine the effectiveness of the
Comptroller's Handbook for National Bank Examiners
e. Review how bank management
23. After making a judgment about the
24. Determine if bank management has demonstrated by its actions whether it believes customers' interests are critical to all aspects of its nondeposit investment product sales programs.
25. Discuss significant findings with the EIC and bank management and prepare written comments.
Retail Nondeposit Investment Sales Internal Control Questionnaire
• Enhanced operational support?
15. Does the analysis of fixed and variable rate annuities include a determination of the credit quality of the issuing insurance company?
16. Does the analysis of fixed and variable rate annuities include determining whether the issuing insurance company can sell or simply transfer the annuity contract to another insurance company?
Use of Customer Information
17. Do written policies concerning the use of information about bank customers address:
• The minimum standards or criteria for identifying a customer for solicitation?
Acceptable calling times?
• The number of times a customer may be called?
The steps to be taken to avoid confusing depositors about the nature of the products being offered?
Setting and Circumstances of Nondeposit Sales
18. Has a bank officer been assigned responsibility for reviewing all current and planned nondeposit investment sales locations to determine whether appropriate measures are in place to minimize customer confusion?
19. Are nondeposit investment products sold only at locations distinct from where deposits are accepted?
20. Are sales locations distinguished by use of:
• Distinguishing partitions, railings, or planters?
21. If personnel both accept deposits and
Comptroller's Handbook for National Bank Examiners Temporary Insert — February 1994
sell nondeposit investment products, do operating procedures address safeguards to prevent possible customer confusion?
22. Are the people who sell nondeposit investment products distinguished from people who accept deposits by such means as:
• Name tags or badges?
23. Do operating procedures prohibit tellers from offering investment advice, making sales recommendations, or discussing the merits of any nondeposit investment product with customers?
24. Does the bank offer nondeposit investment products with product names that are not.
Identical to the bank's name? • Similar to a deposit product?
(Example: XYZ Money Market Fund vs. XYZ Money Market Account.)
25. Does the bank avoid using the words "insured," "bank," or "national" in product names?
Disclosures and Advertising
26. Has bank management designated an officer to be responsible for ensuring that bank-prepared investment advertise.nents and advertisements prepared by any other party are accurate and include all required disclosures?
27. Is a signed statement acknowledging
disclosures obtained from each customer at the time that a retail nondeposit investment account is opened?
28. For accounts established prior to the issuance of the Interagency Statement, are procedures in place to ensure that such a signed statement is obtained prior to, or at the time of, the next transaction?