I posted last week to inquire about where is common to place NDIP flyers in the bank branch. I know the regs say to segregate the area, but does anyone allow unlicensed tellers to hand-out flyers to customers who are performing a deposit transaction? I am trying to tighten up my NDIP compliance and am getting a lot of push-back from the the branch operations because teller's get referrals if they direct a customer to the insurance representative.

Please let me know your thoughts.

While there is a lot of grey in the NDIP regs, one thing is very clear. You must never, never mix NDIP ads with a deposit-taking function. That's the long way to say NO! If you are going to compensate the tellers for referrals, the tellers are going to have to work a little harder. And, they are going to have to get lots of training.

Thanks for your answer. I was pretty sure that I was on base with my interpretation. Here is another quick one...do you really need the "May Lose Value" disclosure on a Term Life Insurance Ad? I know that the guidance says you need all the disclosures, but if you have an add just for term life, that "May Lose Value" phrase makes no sense because term life cannot lose value.

Lucy, I agree with you. However mgmt is of the opinion that generic info brochures about the investment program are ok because they do not describe rates, terms, fees, etc.

I disagree - what do you think?

I disagree also.

NDIP brochures on/in the Teller area is a sure fire way to bring examiner attention. I agree with the previous post(s) - your tellers are free to make referrals, but if they (and your sales people) are trained properly, they will not need brochures or advertisements at the teller line to get a successful referral.

The opinions expressed are mine and not those of my employer.

The issue is not about whether customers will be confused about rates and return. The issue is whether customers will be confused or misled about deposit insurance coverage. This has nothing to do with mentioning any specifics. That would be Regulation DD stuff. Don't be misled by the difference. Having tellers -- who are practically icons for deposit insurance (with those lovely FDIC Insured signs at their windows) hand out NDIP ads, however generic, is asking for a lawsuit when the market drops. And since the market seems to only know how to go down at the moment, your management shouldn't be interested in attracting a lawsuit.