BSA Guidelines for Night Depository Vaults

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Question:

Does the FDIC’s Bank Secrecy Act provide any specific security standards relating to Night Depository Vaults?

Answer:

Excellent question. We recommend that you review this question with your legal or compliance team; however, we believe that the BSA does establish minimum security standards for Night Depository Vaults – under the discretion of the designated Security Officer. Those standards include a (1) vault or safe, (2) alarm system, (3) adequate lighting inside the building, and (4) a camera based on risk, costs and other security measures and physical characteristics of the branch office.

Subpart A – Minimum Security Procedures, § 326.3 Security program setting forth security standards. The Security Program shall: provide for selecting, testing, operating, and maintaining appropriate security devices as specified in paragraph (b) of this section: Each institution shall have, at a minimum, the following security devices (condensed and paraphrased):

A means of protecting cash or other liquid assets, such as a vault, safe, or other secure space.

An alarm system or other appropriate device for promptly notifying the nearest possible law enforcement officers of an attempted or perpetrated robbery or burglary.

Such other devices as the Security Officer determines to be appropriate, taking into consideration:

The incidence of crimes against financial institutions in the area
The amount of currency or other valuables exposed to robbery, burglary, and larceny
The cost of security devices
Other security measures in effect at the banking office, and
The physical characteristics of the structure of the banking office and its surroundings

Other considerations that may be applicable include: (a) a lighting system for illuminating, during the hours of darkness, the area around the vault, if the vault is visible from outside the banking office, and (b) maintaining a camera that records activity in the banking office.

This Q&A originally appeared in Bankers' Hotline. For more information, sample issues, and to subscribe, click here or email bh@bankersonline.com