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We are contemplating closing a branch that has rented safe deposit boxes. We plan to notify safe deposit box customers that we are closing the branch, and that they can transfer their safe deposit box accounts to a new location. Customers who wish to do so will remove their safe deposit box contents themselves. For customers who do not respond to our notice, we plan to drill the boxes, remove and inventory the contents, and then hold the contents in the vault of another branch. Our attorney has suggested that we video record the box openings, in addition to having two employees present, in order to defend against any claims that items are missing. Do you have any additional guidance on how we should handle safe deposit boxes for customers who do not respond to our notice? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We are contemplating closing a branch that has rented safe deposit boxes. We plan to notify safe deposit box customers that we are closing the branch, and that they can transfer their safe deposit box accounts to a new location. Customers who wish to do so will remove their safe deposit box contents themselves. For customers who do not respond to our notice, we plan to drill the boxes, remove and inventory the contents, and then hold the contents in the vault of another branch. Our attorney has suggested that we video record the box openings, in addition to having two employees present, in order to defend against any claims that items are missing. Do you have any additional guidance on how we should handle safe deposit boxes for customers who do not respond to our notice?

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We agree that you should guard against potential claims that items are missing if you open any safe deposit boxes and transfer their contents without customer approval, and we think your bank counsel is providing you with sound advice in this regard.

We do recommend that you review your safe deposit box agreement to determine whether any of its provisions also could be interpreted to apply to this situation. Also, we recommend maintaining records of all notices that you send out in case any issues arise later regarding any of the boxes transferred by the bank.