- In-house VOW: If a firm develops, maintains and operates its own VOW, then the compliance review will occur before the VOW starts operating through the RLS. Future compliance reviews will be conducted only when a formal complaint is filed with REBNY against the VOW
- Customized AVP: The requirements for firms using an AVP product customized for that firm will be the same as those for an In-house
- Non-Customized AVP: REBNY will waive the initial compliance review for a firm using a non-customized, off-the-shelf AVP product that has already passed a compliance review. Future compliance reviews will be conducted only when a formal complaint is filed with REBNY against the
The initial compliance review, however, will not be waived for a firm using an AVP’s non-customized product that has yet to be reviewed by REBNY.