Safe Deposit Box Compliance

We all know safe deposit boxes are an essential part of many financial institutions, but did you know that neglecting their proper maintenance and security measures can lead to compliance and legal issues? In this session, we’ll explore the importance of having detailed procedures and strong controls for opening and maintaining safe deposit boxes.

Safe deposit boxes may not seem like a flashy area of banking, but don’t let this regulatory “sleeper” fool you. Examiners have cited findings for lack of sufficient policies and procedures and inadequate controls. Quite simply, these are areas that we tend to “set and forget” and it’s reflected in our examination reports. Are you properly monitoring for suspicious activity in your SDB area? What happens if an SDB lessee passes away? When is it okay to drill a box and when isn’t it? When do unclaimed property rules apply? If you hesitated in answering any of these questions, then this session is for you!

Learning Objectives:

• Understand risks associated with your safe deposit boxes, including security, compliance and BSA
• Detail the differences between opening SDBs for consumers, businesses, trusts and estates
• Develop a detailed process for when rent is past due
• Follow appropriate procedures for when a lessee passes
• Monitor for suspicious activity
• Determine when box contents are considered abandoned property
• Utilize provided tools to audit and review your safe deposit boxes

Intended Audience:

This jam-packed session is designed for New Accounts Personnel, Branch Staff, Risk Officers, Compliance Officers and anyone responsible for managing your safe deposit boxes.