Internal Control Questionnaires and Verification Procedures

Program Management

1. Has the bank’s board of directors adopted a program management statement that addresses:

   1. The features of the sales program?

   2. The associated risks?

   3. The roles of bank employees?

   4. The roles of third party entities?

2. Do the bank’s policies address the following issues:

   1. Program objectives?

   2. Strategies to be employed to achieve objectives?

   3. Supervision of personnel involved in nondeposit investment sales programs?

   4. Supervisory responsibilities of third party vendors who are selling on bank premises?

   5. Selection of the products the bank will sell?

   6. Permissible uses of bank customer information?

   7. Communications with customers?

   8. The setting and circumstances of nondeposit product sales?

   9. Disclosures and advertising?

   10. Suitability of recommendations?

   11. Employee qualifications and training?

   12. Employee compensation systems?

   13. A compliance program?

3. Do written supervisory procedures assign a manager the responsibility for:

   1. Reviewing and authorizing each sale?

   2. Accepting each new account?

   3. Reviewing and authorizing all sales or account-related correspondence with customers?

   4. Reviewing and authorizing all advertising and promotional materials prior to use?

4. Does the bank use written job descriptions to assign management responsibilities?

5. Do policies and procedures for personnel who are not directly involved in nondeposit investment product sales detail what the employees may say and not say about investment products?

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