TO: All BISA Members
FR: Richard D. Starr — LRC Committee Chairman
DT: 18 September 2007
SB: Sales Seminars, Lunches and Promotion Sales Events

Selling to seniors using "free lunch" or "free dinner" promotions has come under close scrutiny by the SEC. Regulators are focusing on these seminars that are promoted as "information only," but that are often sales seminars for unregistered securities products.

BISA has discussed these promotions at its meetings, and has been concerned that these types of promotional selling will reflect poorly on all retirement income strategy programs of its members. I have provided a link to the SEC release addressing this topic and urge all BISA members and their affiliates to be aware of these seminars in their communities and make regulators aware them. If you currently used any type of seminar selling for any product, registered or unregistered, please carefully review the applicable rules and regulations and ensure your firm has the supervisory controls in place to oversee and manage their delivery.

See: www.sec.gov/news/press/extra/seniors/freelunchseminars.htm