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#1329810 - 01/25/10 02:30 PM Safe Deposit Boxes as covered accounts
happyauditor Offline
Platinum Poster
happyauditor
Joined: Nov 2004
Posts: 809
NY
I am taking a poll to see how many banks have identified safe deposit boxes as covered accounts. Please answer YES or NO (no need to identify your bank).

Any other information you would like to add that you feel is helpful (such as the reasoning behind identifying it or not as a covered account) would be appreciated. Thanks.

For reference, here is the definition of covered account:

(3) Covered account means:

(i) An account that a financial institution or creditor offers or maintains, primarily for personal, family, or household purposes, that involves or is designed to permit multiple payments or transactions, such as a credit card account, mortgage loan, automobile loan, margin account, cell phone account, utility account, checking account, or savings account; and

(ii) Any other account that the financial institution or creditor offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the financial institution or creditor from identity theft, including financial, operational, compliance, reputation, or litigation risks.
_________________________
* My opinion is not necessarily that of my employer.

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#1330347 - 01/25/10 08:31 PM Re: Safe Deposit Boxes as covered accounts happyauditor
one deer Offline
Member
Joined: Aug 2004
Posts: 77
Any where but work
NO

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#1330488 - 01/25/10 10:04 PM Re: Safe Deposit Boxes as covered accounts one deer
OkieDokie Offline
Junior Member
Joined: Jan 2007
Posts: 45
Oklahoma
No
While performing our risk assessment, the FDIC had a teleconference, and I called one of the panelists. I asked about SDBs, CDs, and Trust accounts and in our Bank the FDIC person agreed with our risk assessment of low risk, mostly due to no transaction activity. He agreed there was no reason to include in our ID Red Flag Program Procedures. We were recently examined by the FDIC and they seemed to be OK with our risk assessment.

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#1331698 - 01/27/10 02:34 PM Re: Safe Deposit Boxes as covered accounts OkieDokie
happyauditor Offline
Platinum Poster
happyauditor
Joined: Nov 2004
Posts: 809
NY
thanks for your responses!
_________________________
* My opinion is not necessarily that of my employer.

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