GLB – documents locked-up - We recently had a training session on GLB and document lock-up was discussed.
Due to the nature of our business line (residential mortgage lending), it would be extremely difficult for everyone to clear their desks, and put away all files and papers daily. It would mean additional cabinets in an already crowded area, and lack of productivity, especially with underwriters who have multiple files out that they are working on.
Our building is “almost” secure. The only person who is allowed-in and not physically escorted is the cleaning person. To comply with GLB could either of these be used:
Arrange someone’s schedule to be with the cleaning person when he is in the building. This would mean altering someone’s schedule to come in late and leave when the cleaning person is finished.
Have the cleaning person become an employee of the bank. As an employee, it would be permissible for them to be around the documents.
Would either of those work, or might there be other things we can try? There is just no additional room for cabinets, nor the budget to buy them.