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#2058780 - 01/14/16 08:59 PM Logging of Safe Deposit Box Visits/BSA
BSAAnonymous Offline
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Joined: Feb 2012
Posts: 165
I am in the state of NY. It was brought to my attention that the logging of safe deposit box visits is not a requirement. However, in the FFIEC Manual it talks about suspicious activity regarding safe deposit box visits. I've seen subpoenas request a printout of safe deposit visits conducted by a customer. Anyone in NY not log safe deposit box visits and how do you document and monitor for potential suspicious activity regarding a safe deposit box? Thank you in advance.

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#2058792 - 01/14/16 09:20 PM Re: Logging of Safe Deposit Box Visits/BSA BSAAnonymous
edAudit Offline
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edAudit
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I am no longer in a Safe deposit branch but In a prior we did not log it at all as there is no law or suspicious activity that can be determined by having such a log.

We were nudged into keeping a log by the examiners. So we kept a paper one attached to a card followed by an enter the time and date into a bank standalone program.

FWIW had an elderly customer who would go to the box daily we though that she napped in the room.

Another customer who would have lunch in the room also daily.

Had a customer who was found to be a drug dealer who never visited the box.

Another customer had other really bad issues and never went into the box except for opening it. We had to do a box inventory and found it to be full of collectable coins (very large sum of money even for him).

Had another customer who was an exotic dancer who opened the box in front of staff it was filled with singles (not even enough for a CTR a small sd box) she visited the box weekly
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#2058874 - 01/15/16 02:29 PM Re: Logging of Safe Deposit Box Visits/BSA BSAAnonymous
Elwood P. Dowd Offline
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Posts: 21,939
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Safe deposit box custodians kept entry logs long before BSA/AML was even a gleam in someone's eye. They did it for their own protection in the case of an alleged "mysterious disappearance" of the renter's property. Eliminating the log would be a pretty avant garde move in my book; it would enhance the custodian's risk without providing any significant savings.

Until your post, it would not have occurred to me that a custodian would consider omitting the log or that one of the reasons for retaining it would be AML considerations. Now, if the proponent(s) of eliminating the log even mouth the words "customer privacy" I'm convinced they have wandered into an area of the bank where they have neither experience nor expertise. Give them a lollipop and send them back where they came from.

I'm interested to see how others respond.

P.S. Check NY record retention requirements for safe deposit access. If there are some (very likely) that might be your best argument against the uninitiated that you are required to document access. (Actually, what it probably means is that if you have the record you have to keep it, not that you have to have it.) What it does for sure is make you look incredibly sloppy for not keeping records at all.
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#2058894 - 01/15/16 03:44 PM Re: Logging of Safe Deposit Box Visits/BSA BSAAnonymous
BuckDog Offline
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Joined: Jun 2006
Posts: 123
Tennessee
We have entry cards with signatures of those authorized to enter that are on the contract. The person signs the card in front of the bank employee, the employee initials, dates and enters the time. For most of our branches it still takes the bank key and the customer key to open the box. An employee is also requested to survey the area to make sure there is nothing that the customer might have left out of the box. We had an issue several years ago where an individual claimed a large sum of money was missing from his safe deposit box. Because of our procedures, we could show him that it was improbable for anyone employed by the bank to have gained access nor anyone else without our knowledge. He later found the money crammed in the back of the box. Sometimes our procedures are our only defense. A review of entry cards when we do an audit shows whether the branch employees are following procedures.

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