Internal Control Questionnaires and Verification Procedures

Setting and Circumstances

1. Has a bank officer been assigned responsibility for reviewing all current and planned nondeposit investment sales locations to determine whether appropriate measures are in place to minimize customer confusion?

2. Are nondeposit investment products sold only at locations distinct from where deposits are accepted?

3. Are sales locations distinguished by use of:

   1. Separate desks?

   2. Distinguishing partitions, railings, or planters?

   3. Signs?

4. If personnel both accept deposits and sell nondeposit investment products, do operating procedures address safeguards to prevent possible customer confusion?

5. Are the people who sell nondeposit investment products distinguished from people who accept deposits by such means as:

   1. Name tags or badges?

   2. Business cards?

6. Do operating procedures prohibit tellers from offering investment advice, making sales recommendations, or discussing the merits of any nondeposit investment product with customers?

7. Does the bank offer nondeposit investment products with product names that are not:

   1. Identical to the bank’s name?

   2. Similar to a deposit product? (Example: XYZ Money Market Fund vs. XYZ Money Market Account.)

8. Does the bank avoid using the words “insured,” “bank,” or “national” in product names?

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