After experiencing a more than 50% increase in variable annuities (VA) sales last year, banks must pay careful attention to supervising sales of VAs at their branches through affiliated broker-dealers (BDs). Under today's risk-based examination approach, such a large sales jump invites targeted examinations by regulators - and extraordinary scrutiny.
Effective supervision begins at the top, with clearly delineated lines of responsibility, reflected in written organizational charters, and detailed written descriptions of each position's precise responsibilities. Many institution-rattling scandals arose from a lack of this precision. If duties and responsibilities are misunderstood at multiple levels, violations may start or continue unnoticed.
The …
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