We're relocating a branch on a military installation next month. We've run the DoD check against the remaining 27 boxes and have 5 leased to active duty servicemembers. We won't have building access after we move, so we have to drill the boxes if we can't get the remaining 27 taken care of prior to the relocation. The question we're debating, fortunately with our Legal Dept, is whether we can drill the lock, remove the boxes leased to the people on active duty, and seal each box under dual control without opening it, and store it at the new location in a vault under dual control until they come back. No seizing contents, no escheatment, etc. I said "just get a court order" and Legal said "but does this actually meet the definition of a seizure"? I think Legal makes a good point. We just have to relocate and secure the boxes.

Thoughts? We're out of that building and into a new one sometime in mid-late June. Those boxes have to come with us to the new location. Someone, probably Legal and me, will have to explain this to the OCC at the next exam.

I would agree that the bank is neither enforcing a storage lien or foreclosing on this and it is a case of ensuring the contents are under dual control and safeguarded at all times. No harm, no foul.

Thanks, Andy! We really hope we're going to be able to make contact, even if they're over in the sandbox. We were able to get current email addresses from our contact. The downside is that if they can't come get the contents, the plan is to move them halfway across the country to our HQ branch for secure storage. I think we need to do the standard inventory of contents under dual control before sealing them though, possibly in view of a video camera so that we're fully protected and know what we're shipping. That's giving me privacy headaches...