Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
We plan to close the lobby at one of our branches but maintain drive-through services. What should we do about the safe deposit boxes at that branch? We plan to notify safe deposit box customers that the branch will be accessible only via the drive-through and that they can transfer their safe deposit box leases to one of our other locations. How much notice should we provide? What if a customer does not respond to our notice? When can we drill the box? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We plan to close the lobby at one of our branches but maintain drive-through services. What should we do about the safe deposit boxes at that branch? We plan to notify safe deposit box customers that the branch will be accessible only via the drive-through and that they can transfer their safe deposit box leases to one of our other locations. How much notice should we provide? What if a customer does not respond to our notice? When can we drill the box?

—

by

We are not aware of any notice requirement for moving safe deposit boxes, unless there is an applicable provision included in your safe deposit box account agreement.

Likewise, we are not aware of any law that directly addresses drilling a safe deposit box when the owner is alive and the account is current, which would be the case here. Whether and when you may drill in this situation depends largely on the language in your account agreement. If you drill a box in violation of the terms of your account agreement, your bank may face liability for breach of contract. We recommend consulting with your bank counsel to determine your bank’s rights and responsibilities with respect to drilling a box for a living customer whose account is current.

If your account agreement permits your bank to drill a box in the situation you have described, we recommend video recording the box openings, in addition to having two employees present, in order to defend against any potential claims that items are missing. We also 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.