If you provide such service in your trust area, and the customer DOES NOT have the investment discretion, do we need the NDIP disclosure??
My point is not all sales of nondeposit investment products are subject to the Interagency statement.....
please help
thanks..

If the activity is being conducted in the trust area that is a part of the bank and you are not holding yourself out as a Registered Investment Advisor under the '40 Act - then No I don't think you need the NDIP disclosure.

But, if the activity is being conducted in a brokerage or advisory affiliate, then that's another issue entirely.

I suggest you be cautious though of using the FDIC insured logo. Make sure you understand how the insurance calculations work and what the limits are for FDIC coverage on trust accounts. Also, if your bank or an affiliate is receiving 12b-1's, advisory, shareholder servicing, or custodial fees for investments in proprietary funds, make sure you are providing the proper disclosure there.

Thank you so much Karen...