I just recently started reviewing the security round robins we receive in my area because our security officer is out for a bit. I am just wondering what our responsibility is surrounding these requests? For example, we recieved one from the FBI yesterday requesting information regarding specific accounts so they an determine what banks they need to send subpoenas to.

My concern is Privacy... what are our responsibilities when it comes to these kind of requests?

What is a "round robin"?

ha...I just assumed everyone in the security world would know. Anyway...it is from the local security officer's assocation. Various things are reported on round robins. The security officers association is made up of various local banks/ CU's and law enforcement. Sometimes the round robins are requests for information by the police on specific people or some are just "caution, don't open an account for Jane Doe".

But...my question is on the ones that are requesting more info to be provided to police on specific people. How is the bank protected if we provide that info? I personally don't think we should be doing anything of the sort without a subpoena. BUT, the one I got yesterday requesting information from the local banks regarding a specific account. We are supposed to report back to the FBI so that they can just turn around and send a subpoena.

I just don't feel comfortable...and this is now all coming to light now that the security officer is out. I don't think we should be sharing information like that without a legal request!!

UGH. As if BSA wasn't enough, now this!?!??!

If you feel uncomfortable simply request a subpoena for the information. For the FBI, a grand jury subpoena is easy to get, the agent just needs to make a phone call to an AUSA and then request the subpoena be faxed to you. Once you receive it, release away without concern.

Unless the RFPA has changed recently, you can disclose that you have an account for a particular customer, and you can disclose the customer ID information. You just cannot disclose any details about the account or provide any account documentation without a subpoena. It is done all of the time in "round robin" type situations. That is one way local bank fraud working groups can function effectively.

We do this ~Round Robin~ In Oklahoma City and we call it MAFIA which stands for
Metro
Fraud
Investigators
Association
It is a very useful tool and a great place to network. We meet once a month and usually have 50 people or so attend from the banking industry, retail and law enforcement. It is awesome.

We too have this scenario and get requests from local law enforcement either in the form of a phone call or e-mail request. They know something is "up" when we respond: I think you might want to send us a subpoena....