Do banks have to change the locks after someone surrenders their box? If yes, do we have to have extra locks or can we exchange with another unused box? Or can we just not use the recent surrendered box for awhile? Our one problem is that our boxes are from two different vendors, so some keys have the box number engraved on them. Can we make new keys? I really need help with this because I'm reviewing our policy that was done by an employee that is no longer here. Thank you!

Do the keys you issue to your customer say "do not duplicate?" Also, it should still take one bank employee to submit the bank key after identifying the correct customer/box, so I don't see a need to change. I have never worked at a bank where we changed the locks after a customer stopped using a box.

Our keys do not say "do not duplicate" but our contracts say that the customer (lessee) can't duplicate the keys. We are a smaller bank and I agree that we know our customers. If we are unsure, we would look at identification.

I would love not to have to change the locks but I don't want to be questioned about this by examiners. Thanks for your input TheGilmore!

We issue two keys, if BOTH keys are turned in, we do not change locks. If only one key is turned in or no keys turned in, we do.

That makes sense. Thank you.

Even though a customer brings in both keys, it does not mean that a duplicate key has not been made.

Years ago reputable locksmiths would not duplicate SDB keys. But we discovered that is no longer the case when one of our customers surrendered three keys. They had made the duplicate key themselves at one of the chain hardware stores.

We rotate locks.

Safe deposit boxes are generally governed by "best practices," not legal requirements. This is a good example.

Changing locks before box is rented again is absolutely the best practice. However, it is cost prohibitive unless you have a modern system where the locks can be changed by bank personnel with a minimal amount of training and effort. The intricate procedures for key handling and surrender are what you implement if you decide you simply cannot change locks every time a box is surrendered.

Thanks for all the input. Since we are not that big and don't have much of a turn-around on the boxes, I think we can justify not changing the locks. Thanks again!