Do you know of any best practices for Safe Deposit Boxes that the bank uses instead of renting out to customers?

Specifically, are there any requirements as far as the signature cards & access entry cards go for documenting employees' access to those boxes?

We want to show them on our core system as used by the bank, but not entirely sure how to document this if we allow any two employees to access one of those boxes.

Sounds like an internal issue. What does your core system have to do with access logs?

I am also not sure if "we allow any two employees to access one of those boxes", why you need what there is in the box in a safe deposit box, since I am not sure how you maintain dual control in that case.

Our core system would show the box rented to the bank and documents who has access to the account.
This helps show what available inventory would be left when someone wants to rent a new box.

Our core system also is used to generate the signature card reflecting who has access. Our entry cards are not generated from our core and are easy to customize. They do not want to change the signature card/entry card every time employees leave or new ones are hired. They would like to have a generic statement instead saying 2 employees.

I would anticipate the use of the SDB keys being kept in a dual control key box (or something similar) which would then need to be signed out. I would also expect the two employees to sign the entry card showing they accessed the SDB.

Are you aware of any regulatory requirements that would prevent us from moving forward with what they are wanting to do?

I am not aware of anything in any State that would limit how you handle the internal use of safe deposit boxes. It is all going to come down to bank policy and procedures. I assume these boxes would be keyed differently than your rented customer boxes, as far as the master key is concerned.

I'm honestly not sure about the master key being different from other boxes. Thank you for your responses. We will discuss internally what would be best practice since there doesn't seem to be anything regulatory wise preventing it.

I worked at a bank that had bank use safe deposit boxes. They were keyed different and didn't use the master key. Half the employees had one side and the other half had the other side. We had a separate log where both employees would sign with the date and purpose of entering the box.