We have hired discount brokers at the bank and set them up as "Dual Employees" in the bank for compensation reasons. These employees sell NDIP products in the bank to our customers and others requesting these type of products, but we have authorized them not to open bank insured FDIC accounts at the bank. Are the NDIP products they sell to our bank customers deemed "Covered Accounts" and subject to the risk assessment and part of the Idenity Theft Prevention Program we are requred to have at the bank?

Thanks