I have been reading through Angela's thread regarding the new insurance rules. I have another question that maybe someone out there can address.
Our employees who sell annuities are "dual" employees of both the bank and our affiliated insurance company. When they sell these products, they are not working for the bank. The bank provides a physical place for these sales to take place, but the insurance company, not the bank receives fee income from the sale. If referrals are made from the teller line or the platform, these referrals are made to the investment person, but not for any specific product or service. In fact, non-licensed bank employees are prohibited from recommending any product. As an insurance employee, our investment people give all the appropriate disclosures required, but these are furnished by the company underwriting the annuity, like GE Capital. The customer signs and dates the disclosures and a copy goes into the file. We cannot give that person a disclosure that has the bank's name on it, and nothing with the bank's name or logo is allowed to be placed in the file. The bank is not selling the product, and is not recieving any fee or commission from the sale . So, do we fall under this rule or not? If so, how do we comply?
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