Bank Protection Act Changes-More Work For The Super Security Professional

Comment is to be to the Federal Reserve Board of Governors by June 4 on the revision on Reg P (Minimum Security Devices and Procedures). EDITOR'S NOTE: This article was originally written in 1990. In the mid-90s, the Federal Reserve moved the provisions relating to bank security from Regulation P to Regulation H. In 2000, Regulation P became the privacy regulation.

The proposed regulation establishes a minimum standard by requiring four specified security devices.

These four devices are:

A secure space for cash
A lighting system for illuminating the vault
An alarm system
Tamper resistent locks on exterior doors and windows

In addition, the proposed regulation establishes the contents of a security program. Included must be procedures:

for opening and closing for business
for safekeeping of valuables
for identifying persons committing crimes
for providing initial and periodic training of employees in security and in their conduct during and after a robbery.

These are the minimum procedures that should comprise an institution's security program.

To ensure that the security program is reviewed on a regular basis for effectiveness, the proposed regulation requires a report to be made by the security officer to the board of directors at least annually. This changes the current requirement, which was eliminated by FIRREA, that reports must be filed periodically with the institution's primary supervisory agency.

These are the major changes to Reg P. If you do not have a copy of the entire regulation and comment distributed by the Federal Reserve Board of Governors and would like one, give us a call and we will send a copy to you.

Copyright © 1990 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 1, No. 5, 5/90