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Safe Deposit Boxes in the Lobby

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Question: 
My bank is exploring the possibility of putting safe deposit boxes in the lobby similar to a post office box. I outlined the obvious SDB101 hazards including lack of secure storage, lack of dual control, potentially public viewable contents, the potential threat to proper documentation of access and liability. Are you able to quote a law or regulation that outlines and requires such prudent safekeeping practices?
Answer: 

The purpose of a safe deposit box is security and privacy. Management needs to ask if they feel this can be delivered in the lobby. I am not aware of specific regulatory requirements, but the FDIC does say this:

FDIC Publications —FDIC Handbooks —Manuals —Examination Procedures —Guides —FDIC
Instructions for the Preparation of the Report of Examination — Federal Deposit Insurance Corporation, August, 1996 —RELATIONSHIPS WITH AFFILIATES AND HOLDING COMPANIES SUPPLEMENTAL PAGE 8 , Part 01 of 04
the bank assumes the responsibility of exercising reasonable care and precaution against loss of the box's contents. If a loss does occur, the bank may be liable unless it can demonstrate it has maintained the required standard of care. The required standard of care is defined as that which would be taken by a reasonably prudent and careful person engaged in the same business. The bank must also preserve privacy of entry into the boxes. Two different keys are required to open the box, and the customer and the bank each have one. The customer is not required to disclose the contents of the box to the bank. Only upon a court order may the bank gain access to the box without the presence of the customer.

First published on BankersOnline.com 12/01/08

First published on 12/01/2008

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