In the United States, banks are exempt from registration with the Securities and Exchange Commission (SEC) under certain conditions when engaging in certain securities-related activities. However, the exemption does not apply to activities that go beyond traditional banking activities.
Variable-rate savings accounts are NOT subject to the disclosure provisions of the Interagency Statement on Retail Sales of Nondeposit Investment Products.
The policy stating that tellers and new accounts personnel will receive a $25 fee for all customers referred to the nondeposit investment department on the customer's purchase of an investment product does NOT comply with the Interagency Policy Statement on the Retail Sales of Nondeposit Investments.
Under the Interagency Statement on Retail Sales of Nondeposit Investment Products, the bank's investment sales representative must disclose to the customer that the investment product is not guaranteed by the bank.
While it may be challenging for tellers to handle multiple types of products, ACME Bank's decision to have tellers help sell insurance products to new and existing customers raises potential concerns.