This document describes the overview of nondeposit investment products (NDIP), including objective, scope of NDIP, networking arrangements, and management responsibility.
This document is an excerpt from the FFIEC BSA/AML Examination Manual, specifically covering Nondeposit Investment Products (NDIP). It outlines the objective of assessing bank systems for managing risks associated with NDIP, such as securities, bonds, and annuities. The text details various networking arrangements, including co-branded products, dual-employee arrangements, and third-party arrangements, explaining how they affect Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) responsibilities.
NDIP include a wide array of investment products such as securities, bonds, and fixed or variable annuities.
The U.S. Securities and Exchange Commission (SEC) is the primary regulator for NDIP offerings through broker/dealers.
In a dual-employee arrangement, the bank retains responsibility over NDIP activities even if the financial services corporation is responsible for BSA/AML.