Q: What does the FDIC consider when evaluating personnel qualifications, monitoring and audit function evaluations?
A: Pursuant to the FDIC manual, considerations would include the following:
Insurance sales employees and management are qualified (appropriate licensing, training, and/or experience) to conduct their authorized duties.
The institution's insurance sales training materials appropriately cover the requirements for referral and sales activities, including any appropriate and inappropriate customer referral activities.
Does the institution conduct monitoring of its retail insurance sales program and that of any third party?
Does the monitoring include sales practices, the referral process, the manner and timing of disclosures, and customer acknowledgement of receiving disclosures?
Does the institution review customer complaints to identify compliance issues?
Audit Function Evaluation
Consider whether the institution’s audit program includes its retail insurance sales program, including third party activities, and assess the audit program’s effectiveness.