Our customer service representatives are being cross-trained to sell loan products. They will also sell credit protection products in conjunction with the loan products. In reading the regulatory guidance associated with insurance sales (NDIP), it requires that insurance sales should be conducted in a separate and distinct location from deposit taking functions to the extent practical from deposit taking areas. During the deposit account opening process our CSRs do accept the initial deposit and they also have FDIC signage on their desks. I'm just wondering how other banks are handling this practice where you have frontline bankers selling both loan and deposit products and also offer credit insurance.

NDIP is for investment products that can lose value and are not insured by the FDIC, which is different than the credit life/disability that a lot of places sell. Are those what you're refering to?

Yes, but it was my understanding that the rules applied to both areas.