Key issues for bank and bank holding company compliance and risk managers to address in designing and updating their insurance and annuity sales programs are •  Preventing conflicts of interest - ensuring that sales are suitable in light of customer needs and that appropriate alternative products are adequately considered;  •  Monitoring consumer complaints regarding sales practices, and identifying and addressing trends and issues that may expose the banking organization to potential loss;  •  Implementing the Consumer Protection in Sales of Insurance Regulation, upon which I will elaborate in a moment;  •  Ensuring that the parent bank or bank holding company have in place appropriate controls over accounting and other systems, including disaster recovery programs related to the insurance sales line of business;  •  Ensuring that the bank or bank holding company has controls to protect the privacy of customer information, consistent with relevant state or other regulations;  •  Monitoring claims and potential exposures from mistakes - “errors and omissions” - related to insurance sales and brokerage activities, and identifying and reporting to banking organization management adverse trends and potential significant legal exposures;  •  Formal reporting to the board and management regarding the risks associated with insurance sales activities and the internal controls used by the organization to minimize potential loss from those risks.
In the event of a judgment that the current growth momentum is more cyclical than structural, the stance of monetary policy would need to reflect a sensitivity to the inevitability of a downturn. On the other hand, the judgment that structural factors predominate would warrant a different policy stance.