The Office of the Comptroller of the Currency will soon arm examiners with a bulletin that will build on recent guidelines for banks that sell investment products in branches.
The bulletin- the latest sign of regulator's interest in mutual funds- will run more than 20 pages, or three times the length of guidelines the Comptroller's Office released in late July.
The guidelines cover such areas as disclosure, advertising, program management, training, and compensation.
The bulletin is expected to be completed in a couple of weeks and will be available to banks.
Banks don't have to wait for it to prepare for exams, said Owen Carney, chief adviser for invesment securities with the Comptroller's office.
"Document where you might not be in compliance, and fix it." he said.
Mr. Carney elaborated on what examiners will be looking for in comments at the Bank Securities Association's compliance and operations conference in Washington.
Examiners expect access to all appropriate records, including those indicating how many complaints a program has received and "the aggressiveness of sales practices," Mr. Carney said.
Examiners will want to know what kind of systems the bank has in place to oversee programs and avoid serious problems.
"If one sales representative goes bad on one transaction, we can live with it," Mr. Carney said. "But if five reps at different locations do something wrong, that's a problem."
Examiners will get a feel for programs by querying banks about the mutual fund and insurance companies they use, and their managements.
They will ask banks to explain why their programs choose some products over others, Mr. Carney said.
Scrutiny of Proprietary Funds
Bank proprietary funds are also in for scrutiny. Examiners will want information that compares these funds with similar products, Mr. Carney said.
The Comptroller's office expects, in the next couple of weeks, to issue a bulletin that will flesh out what examiners should look at when studying banks' investment programs. The Comptroller's office will follow the bulletin with exam procedures.
The regulator has already done some exams based on the guidelines, but exams based on the training for examiners is still under way. It will take time to train examiners, so the quality of early exams "may well be luck of the draw," Mr. Carney said. "You'll find experienced and inexperienced people."