FDIC Signage Dilemma

Question:

Some of the Personal Bankers at our institution are also licensed to sell annuity products to our customers. Very shortly, we will be updating our technology at the Personal Banker desks which will allow them to take and process deposits for our customers. We now find ourselves in somewhat of a dilemma; we know we need to display the FDIC sign at these workstations but know we cannot display this sign where the annuity products are sold. Any guidance on how we can handle both of these types of transactions (sell annuities and take deposits) at one desk and comply with appropriate regulations?

Answer:

You should not handle these at the same desk for the very reasons you provide. The Consumer Protection for Bank Sales of Insurance rules indicate the deposit and insurance sales areas should be separated to the extent possible.

You are right that you need the FDIC signs at these desks for deposit reasons. Having the signs up when conducting insurance sales will only invite trouble from your examiners and potential confusion for your customers. You need to find another desk for the insurance transactions.