FDIC rules in effect since May of 1991 give each FDIC-supervised bank's board of directors wide latitude to select appropriate security devices, especially in light of constant changes in technology. However, recent complaints from several law enforcement agencies indicate that a number of banks are complying with the letter of the regulation while showing some disregard for its intent. These complaints suggest that some banks are maintaining the required minimum security devices but failing to recognize and evaluate the need for additional equipment or procedures. In some cases, we are told, security programs and procedures approved by the bank's board of directors have not been followed. In other cases, security devices apparently have failed to perform as designed due to lack of proper maintenance.
As a result, the FDIC is recommending that banks review their security devices and procedures to ensure both are adequate. A review by local law enforcement officers also may be appropriate. Security devices should be maintained in accordance with the manufacturer's suggested program. By providing adequate security devices and procedures, banks can fulfill their responsibilities to protect employees, safeguard the bank's assets, and aid law enforcement authorities in apprehending and convicting persons who commit crimes against financial institutions. Banks also must recognize the potential liability to customers who may be injured on the banking premises as a result of inadequate security measures.
If you have any questions, please contact your Division of Supervision regional office.
Nicholas J. Ketcha Jr.
Distribution: FDIC-Supervised Banks (Commercial and Savings)