Regulatory Alerts2010-08-26 | ISGC-2010-002-DOBInterpretation of RCW 30.04.010, RCW 30.04.020, and RCW 30.04.280 Regarding Broker/Dealer Marketing Activities
The Washington Department of Financial Institutions issued an interpretation confirming that a registered broker/dealer recommending its national bank affiliate for deposit needs does not engage in prohibited banking activities under state law. The Division determined that such marketing constitutes a mere recommendation rather than the solicitation of deposits, provided the broker/dealer does not receive funds or negotiate terms. Additionally, the letter mandates that all written communications must clearly distinguish the broker/dealer from the authorized bank to prevent public confusion regarding the entity conducting the banking business.
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