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#1585757 - 08/01/11 02:59 PM 401K
Sugarbaker Offline
Gold Star
Joined: Nov 2005
Posts: 265
We are thinking about advertising that customers can rollover their 401K's with us. This is being run as a general ad. The tricky part is that we also have insurance and investment departments.

Technically a rollover could be done on the deposit side (which would require "Member FDIC") or it could be done on the insurance/investment side (which would require the "not, not may" disclosures). Since this is a general ad and we don't mention insurance or investments should we use only the "member FDIC" disclosure and leave off the "not, not may" disclosures or put them all("member FDIC" and "not not may") on the ad?

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#1585770 - 08/01/11 03:21 PM Re: 401K Sugarbaker
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
If you're not advertising NDIP's you don't need the "not, not.." disclosure. Your staff should be trained to obtain a client's opt in before discussing and/or referring a new customer to an insurance/investment rep and appropriate disclosure should be made at that time. I would document the opt-in in writing.
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#1585776 - 08/01/11 03:21 PM Re: 401K BrendaC
Sugarbaker Offline
Gold Star
Joined: Nov 2005
Posts: 265
Our insurance and investment departments are set up as departments in our bank rather than separate entities. With that being said, if we simply refer a customer to speak with them then we would have to have them sign an opt-in, is that correct? Where can I find more information on this and what should the opt-in look like, etc.?

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#1585801 - 08/01/11 03:49 PM Re: 401K Sugarbaker
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Departments of the same bank or subsidiary(ies)? You may be OK in simply referring them over, but I prefer an opt in that says something along the lines of "yes I am interested in learning more about investments...I understand that these ... are not, not..."

It simply helps to keep lines of communication clear and also aids in tracking referrals for any incentive programs that may exist.
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