Topic: Introducing New Products and Services
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We are adding a wealth management division that will be an affiliate of our institution, with a broker who will be a dual employee of the bank and a nonaffiliated investment company. How should we handle sharing customer information with the employee and other privacy issues?
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If the dual employee will be sharing your customers’ information with the nonaffiliated investment company, we believe that you would have to comply with the federal privacy notice requirements and the Illinois opt-in requirements, described below. Since you have indicated that you are looking for a form for the Illinois opt-in requirement, we recommend posting…
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If we would like to start a relationship with a company that has a website that would send potential depositors to our website, with payment for each referral, would that be considered a deposit broker relationship or a joint marketing relationship?
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We recommend that the bank consult with an attorney to determine the structure of its relationship with the company, either as a deposit broker relationship or as a limited marketing relationship. Deposit Broker Relationship We believe that the arrangement we discussed would be considered a deposit broker relationship. A “brokered deposit” includes any “deposit that…
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We just started offering Uniform Transfers to Minors Act (UTMA) accounts. Do we need to update our account terms and conditions to reflect this new type of account?
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We believe that it would be a best practice to update your terms and conditions to ensure that customers agree that the bank will comply with the Uniform Transfers to Minors Act’s terms. We are not aware of any specific requirements for account disclosures in the Act (though it does specify that accounts are titled…