We are not aware of any laws that would require the bank to hold signature cards for dormant accounts in dual control safety deposit boxes. While the Banking Act mandates the Commissioner of Banks to promulgate record retention rules, no such rules have been published. 205 ILCS 5/48.6. And, the federal agencies’ Interagency Guidelines Establishing Information Security Standards leaves the specifics of safeguarding customer information, including physical safeguards, to be established by bank policy.

Also, we note that it may be possible for the bank to adopt an electronic system for imaging signatures (possibly with access restricted to dual control).