I have done a search and I have read OTS' self assessment guide, and really don't even know where to begin to research this issue:
Where can I find out if it is permissible to put NDIP brochures in with our deposit account statements?

I don't think I can cite a reg Maria, but we have taken the position that it can be considered deceptive to mix communications with the customer. The NDIPs are not insured, the deposits are, so we wouldn't mix the two. My little old grandmother wouldn't know the difference, might buy an annuity from us thinking it has FDIC insurance, and there goes our reputation.

Thanks Don, I happen to agree with you, but you know how persistent marketing can be! I was hoping I could find something in writing to put it to rest.

Maria,

We have always taken the approach that this is a no - no. That you want to minimize customer confusion and differentiate insured products from non-insured products. We are OCC, so I could point you to those regs. I think what you want is Thrift Bulletin 23-2. (don't know if this is the right number) You may want to look at Interagency Guidance 12 CFR 14 "Consumer Protections for Depository Institution Sales of Insurance", or possibly 12 USC 92 "Acting as Insurance Agenct or Broker." Plus, for us, the OCC has a handbook (including exam procedures) on Insurance Products and NDIP. I would think the OTS may have this also. Sorry I don't have a better reference for you.

Thanks Deb, I appreciate the references. I think I convinced them anyway...

Maria,

The OTS just posted on its web site an updated section 710 of the Thrift Activities Regulatory Handbook. This section is now called "Networking Arrangements". It used to be called "Nondeposit Investment Sales". There may be something in this document that can help you. Here is a link to it. http://www.ots.treas.gov/docs/74092.pdf

I was just there yesterday anon. Thanks for the tip, no wonder I didn't see it!