Answer:
Answer by Ken Golliher:
The only federal disclosure that I am aware of would be under the GLB privacy regulations. You must provide an the initial copy of your privacy disclosure unless the customer has already received one in connection with another relationship.
Answer:
Answer by Andy Zavoina:
The contract has to be delivered denoting the terms and conditions of the agreement. That and the GLBA agreement Ken described should do it.
One additional document that you may consider is a notice that the contents are not FDIC insured. While this may be common sense to most of us, I understand there are lawsuits pending since the 9-11 disaster where customers lost the contents of safe deposit boxes and claim they were not aware.
Answer:
Answer by Dave McGuinn:
Currently there are five states that have safe deposit regulations that require written disclosure that insurance is not provided by the financial institution or FDIC. A few of these state regulations also require that a sign be posted near the vault to disclose this consumer information.
Because of the current class action lawsuit filed by 1300 box renters in New York City, I recommend that all financial institutions provide this "NO INSURANCE" disclosure to all new and existing box renters NOW!
This disclosure will help your financial institution defend, if you ever experience an unavoidable safe deposit vault disaster.
Unfortunately, floods, hurricanes, earthquakes, fires, bombs, burglaries and other disasters can and have occurred at many safe deposit vaults nationwide.
First published on BankersOnline.com 6/3/02
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