There has been some recent discussion in my bank regarding Bank security requirements and what they are and if we even meet them. I am curious what these requirements are. We have had some things happen in the last week that have brought up some questions to protecting bank employees from robberies as well as meeting those requirements. Can someone tell me what these requirements are?

It depends on your regulator, but the regulatory requirements can be found at 12 CFR 21, 208.61, 326, and 568 for the OCC, FRB, FDIC and OTS respectively.

So meaning if we are FDIC everything, that is where I can look for the bank security requirements?

§ 326.3 Security program.

(a) Contents of security program. The security program shall:
(1) Establish procedures for opening and closing for business and for the safekeeping of all currency, negotiable securities, and similar valuables at all times;
(2) Establish procedures that will assist in identifying persons committing crimes against the bank and that will preserve evidence that may aid in their identification and prosecution; such procedures may include, but are not limited to:
(i) Retaining a record of any robbery, burglary, or larceny committed against the bank;
(ii) Maintaining a camera that records activity in the banking office; and
(iii) Using identification devices, such as prerecorded serial-numbered bills, or chemical and electronic devices;
(3) Provide for initial and periodic training of officers and employees in their responsibilities under the security program and in proper employee conduct during and after a robbery, burglar or larceny; and
(4) Provide for selecting, testing, operating and maintaining appropriate security devices, as specified in paragraph (b) of this section.
(b) Security devices. Each insured nonmember bank shall have, at a minimum, the following security devices:
(1) A means of protecting cash or other liquid assets, such as a vault, safe, or other secure space;
(2) A lighting system for illuminating, during the hours of darkness, the area around the vault, if the vault is visible from outside the banking office;
(3) An alarm system or other appropriate device for promptly notifying the nearest responsible law enforcement officers of an attempted or perpetrated robbery or burglary;
(4) Tamper-resistant locks on exterior doors and exterior windows that may be opened; and
(5) Such other devices as the security officer determines to be appropriate, taking into consideration:
(i) The incidence of crimes against financial institutions in the area;
(ii) The amount of currency or other valuables exposed to robbery, burglary, and larceny;
(iii) The distance of the banking office from the nearest responsible law enforcement officers;
(iv) The cost of the security devices;
(v) Other security measures in effect at the banking office; and
(vi) The physical characteristics of the structure of the banking office and its surroundings.
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-This is what I found. If the bank meets these in some kind of way, then they are technically meeting security requirements.

But then my next question is, even though they are meeting bank requirements, and robberies are still occuring (some a serious threat) is there something that states that "if the procedures that have been laid out to deter robberies, larceny etc., are not working and these situations are affecting the emotional health of the employees. . . " what needs to happen from there? Is it up to the bank to then figure it out, or does the FDIC have a mandatory regulation that would apply?

I would say that you need to also read:

Sec. 326.4 Reports.

The security officer for each insured nonmember bank shall report at least annually to the bank's board of directors on the implementation, administration, and effectiveness of the security program.

It is the board of director's responsibility through the appointed security officer to ensure that the bank has an adequate and effective security program. Whether the FDIC would ever comment on your security program would probably be based on your robbery statistics compared to your peers in the area. Those comments would most likely fall under the basic safety and soundness parameters rather than a specific regulation. Although, if the bank was being operated in a manner that was endangering the employees and the assets of the organization, the FDIC could order anything from cease and desist orders to removal and prohibition orders against management and the board.

Since you are FDIC regulated, you also need to research your State laws for any specific security related laws and regulations they have promulgated.

OK, thanks. You have clarified everything. Thanks for all your help!

We have a local bank branch that was experiencing an unusal number of robberies. Most times the robber fled from the rear of the branch through a small wooded area to a mall parking lot. To counter this, the bank install an esthetically pleasing fence. No more robberies.

Well in the past week we have had 4, and the only thing they are doing is hiring a part-time security guard that will be stationed at the branches 1 a week and putting in die packets. In my opinion, I don't think this is going to help at all. But I am just a little person and my opinion doesnt matter..

Dye Packs do not stop robberies and cost a lot of money. Do you have state-of -the-art digital color surveillance systems? If not, money would be better spent on them.