Question & Answer

Question: We have a lot of elderly customers who would rather have the investment product sales representative visit them than come into the bank. Can we sell the product off-site?

Answer: Off-site sales are permissible. However, the interagency policy statement applies to the transaction. Because the sales rep is removed from the methods the bank has used in its lobby to call attention to the fact that the product is not an insured deposit, the sales rep must communicate this during the visit. The sales rep should take extra steps to be sure that the customer clearly understands the product, its risks, and the relationship of the vendor to the bank.

Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 16 & 17, 12/97