Managment would like to offer an incentive to LO for selling credit life. If total sales reach $3,000 then the top three producers would receive $100, $75 and $50. This incentive would run for 3 months. The insurance company wants to pay the $50 incentive for the 3 months. Is this ok? Our state allows for the payment of "commissions" to licened insurance producers, which our LO are. However, it doesn't define commission. So can we and the insurance company pay this type of incentive to the LOs? Thanks in advance for your help!

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Found the answer in the Interagency Statement on Retail Sales of Nondeposit Investment Products...

Personnel who are authorized to sell nondeposit investment products may receive incentive compensation, such as commissions, for transactions entered into by customers. However, incentive compensation programs must not be structured in such a way as to result in unsuitable recommendations or sales being made to customers.

Seems like I remember something along the line of "the total annual incentive paid to one lender cannot exceed the average of annual pay of all the lenders"

Does that ring a bell to anyone? Maybe that is for Oklahoma?

12 CFR 2 for National Banks.