Personal Commercial Solicitation on Army Installations
This major revision, dated 18 October 2007–
o Changes the office responsible for personal commercial solicitation oversight from the Office of the Adjutant General to the Office of the Assistant Chief of Staff for Installation Management.
o Incorporates DD Form 2885 (Personal Commercial Solicitation Evaluation) and establishes procedures for persons solicited on Army installations to evaluate solicitations (paras 1-4e(4) and 2-1a(4)).
o Requires agents to provide Army personnel with a written reminder that free legal advice is available for active duty military and their family members from the Staff Judge Advocate prior to making a financial commitment (para 2-1a(5)).
o Requires that commercial life insurance products contain written notices to inform Army personnel of the availability and cost of Government-subsidized Servicemen’s Group Life Insurance; the address and phone number of the appropriate State insurance regulator; and that the Government has in no way sanctioned, recommended, or encouraged the product being offered (para 2-2d).
o Prohibits insurance products from being marketed as investments (para 2-2g).
o Requires garrison commanders check with the appropriate State or Federal regulators to determine a sales agent’s license status and complaint history prior to granting permission to solicit on the installation (para 2-5c(2)).
o Requires garrison commanders to review the list of agents and companies currently barred, banned, or limited from soliciting on DOD installations prior to approving insurance and financial product agent’s request for permission to solicit (para 2-5c(3)).
o Prohibits solicitation of any Army personnel in a “captive” audience (para 2-9b).
o Prohibits solicitors from contacting Army personnel by way of a Government phone, fax, or computer (e-mail) unless a pre-existing business relationship exists and the Army member has not asked for such contact to be terminated (para 2-9v).
o Prohibits solicitors from possessing allotment, direct deposit, or any other form or device used by the Army to direct personnel pay to a third party. This includes using or assisting in using a service member’s “MyPay” account or other similar Internet medium for the purpose of establishing a direct deposit for the purchase of insurance or investment products (para 2-11a(6)).
o Requires garrison commanders to report incidents involving licensing, compliance with State or Federal laws, and complaints involving insurance or financial products or how they are marketed to the appropriate State or Federal regulator (para 2-11b(2)).
o Permits temporary as well as permanent withdrawal of solicitation privileges (para 2-11b(5)).
o Prohibits distribution of literature that competes with on-post banks and credit unions (para 2-12).
o Prohibits the use of commercial sponsorship of Army Morale, Welfare and Recreation programs or events as a means to obtain personal contact information for the purpose of follow-on solicitation, unless the individual provides written permission (para 2-13).
o Prescribes procedures under which approved on-post financial institutions and non-Government, noncommercial organizations may provide financial education programs to military personnel (para. 2-14).
o Requires unit financial counselors to encourage Army personnel to seek legal assistance or other advice from a disinterested third party before entering into a contract for insurance or securities (para 2-15c(5)(f)).
o Designates unit financial counselors as responsible to enforce a 7-day, cooling-off period prior to processing life insurance pay allotments for E-4s and below (2-15c(g)).
o Defines personal commercial solicitation as “Personal contact, to include meetings, meals or telecommunications, for the purpose of seeking private business or trade” (glossary).