Internal Control Questionnaires and Verification Procedures

Disclosures and Advertising

1. Has bank management designated an officer to be responsible for ensuring that bank-prepared investment advertisements and advertisements prepared by any other party are accurate and include all required disclosures?

2. Is a signed statement acknowledging disclosures obtained from each customer at the time that a retail nondeposit investment account is opened?

3. For accounts established prior to the issuance of the Interagency Statement, are procedures in place to ensure that such a signed statement is obtained prior to, or at the time of, the next transaction?

4. Is there a tracking system designed to monitor and obtain missing acknowledgments?

5. Are all salespeople provided written disclosure guidelines for oral presentations?

6. Do the guidelines for oral presentations clearly direct the speaker to:

   1. State the required disclosures?

   2. Clarify the bank’s role in the sales process?

7. If ratings are used in promoting certain products, does bank policy indicate whether the bank will disclose ratings changes?

8. If so, does policy indicate how such disclosures will occur?

9. If the bank is selling annuities which can be transferred to another obligor, is this possibility disclosed to prospective customers?

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