FDIC / Retail Insur Sales – What does the FDIC consider when evaluating sales practices, as well as disclosures; advertisements; and acknowledgements?

Compliance > Retail Insurance Sales
Q:  What does the FDIC consider when evaluating sales practices, as well as disclosures; advertisements; and acknowledgements?
 
A:   Pursuant to the FDIC manual, considerations would include the following:
 
Sales Practices
 
Insurance sales practices, including advertising, would not lead consumers to believe that:
  • extensions of credit are tied to the sale of insurance or annuities;
  • insurance or annuities are backed by the federal government; or
  • products that carry investment risk do not do so.
     
The institution prohibits insurance sales practices that discriminate against victims of domestic violence or providers of services to such victims.
 
Disclosures, Advertisements, and Acknowledgements
 
Standard disclosures and advertising contain at least the following minimum content required by Part 343:
  • NOT A DEPOSIT
  • NOT FDIC-INSURED
  • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY
  • NOT GUARANTEED BY THE INSTITUTION
  • MAY GO DOWN IN VALUE
     
Where insurance is offered in connection with a credit application, standard disclosures explain that credit cannot be conditioned on the purchase of insurance from the institution or the consumer’s agreement not to purchase insurance elsewhere.
 
Disclosures are provided consistently with the manner and timing requirements of Part 343.
 
Disclosures are understandable and meaningful, as required by Part 343.
 
The institution obtains the customer acknowlegement of receipt of disclosures as required by Part 343.
 
 
This Q&A was based on information contained in the FDIC’s Consumer Compliance Examination Manual – June 2018, for Retail Insurance Sales, which may be found here:  https://www.fdic.gov/regulations/compliance/manual/9/ix-2.1.pdf
 

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