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F ederal
reserve
Ba nk
DALLAS. TEXAS
of
D allas
75222
Circular No. 81-72
April 9, 1981
AMENDMENT TO REGULATION P
Minimum Security Devices and Procedures
for Federal Reserve Banks and State Member Banks
TO ALL STATE MEMBER BANKS IN THE
ELEVENTH FEDERAL RESERVE DISTRICT:
Enclosed is a copy of an amendment to Regulation P, Minimum
Security Devices and Procedures for Federal Reserve Banks and State
Member Banks, effective March 10, 1981. The amendment is in slip sheet
form and is suitable for filing in Volume II of your Regulations Binders.
To clarify a statem ent made in our Circular No. 81-55, dated
March 16, 1981, and the attached copy of a press release dated March 5,
1981, it should be noted that banks are not required to prepare and retain
Form P -l in their files. This form, used for reporting security devices,
is eliminated with this amendment. State member banks are required to
have a written security program readily available for scrutiny by
examiners.
In order for your Regulation to be complete you should retain
the printed Regulation pamphlet dated January 13, 1969, and the enclosed
slip sheet. The previous slip sheet should be destroyed.
Additional copies of the amendment will be furnished upon
request to the Department of Communications, Financial and Community
Affairs, Ext. 6266.
Sincerely yours,
William H. Wallace
First Vice President
Enclosure
Banks and others are encouraged to use the following incoming W A T S numbers in contacting this Bank:
1-800-442-7140 (intrastate) and 1-800-527-9200 (interstate). For calls placed locally, please use 651 plus the
extension referred to above.
This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org)
B O A R D O F G O V E R N O R S O F T H E F E D E R A L R E S E R V E SY ST E M
MINIMUM SECURITY DEVICES AND PROCEDURES
FOR FEDERAL RESERVE BANKS AND STATE MEMBER BANKS
AMENDM ENTS TO REGULATION P
1.
Effective November 1, 1973, Appendix A of
(A) located so as to reproduce identifiable
Regulation P is amended to read as follows:
images o f persons either leaving the banking office
or in a position to transact business at each such sta
APPENDIX A
tion or window; and
M INIM UM STANDARDS FOR
(B) capable o f actuation by initiating devices
SECURITY DEVICES
located at each teller’s station or window.
(iii)
Installation and operation o f surveil
In order to assure realization of maximum perfor
lance systems providing surveillance of walk-up
mance capabilities, all security devices utilized by a
or drive-in teller’s stations or windows. Surveil
bank should be regularly inspected, tested, and serv
lance devices for walk-up or drive-in teller’s stations
iced by com petent persons. Actuating devices for
or windows should be located in such a manner as to
surveillance systems and robbery alarms should be
reproduce identifiable images o f persons in a posi
operable with the least risk of detection by unauthor
tion to transact business at each such station or win
ized persons that can be practicably achieved.
dow and areas of such station or window that are
v u ln e ra b le to ro b b ery o r la rcen y . Such d evices
(1)
Surveillance systems, (i) General. Surveil
should be capable of actuation by one or more initi
lance systems should be:
ating devices located within or in close proximity to
(A ) eq u ip p e d w ith one or m ore p h o to
such station or window. Such devices may be omit
graphic, recording, monitoring, or like devices capa
ted in the case of a walk-up or drive-in teller’s sta
ble o f reproducing images of persons in the banking
tion or window in which the teller is effectively pro
office with sufficient clarity to facilitate (through
tected by a bu llet-re sistan t barrier from persons
photographs capable of being enlarged to produce a
outside the station or window. However, if the teller
one-inch vertical head-size of persons whose images
is vulnerable to larceny or robbery by members of
have been reproduced) the identification and appre
the public who enter the banking office, the teller
hension o f robbers or other suspicious persons;
should have access to a device to actuate a surveil
(B) reasonably silent in operation; and
lance system that covers the area o f vulnerability or
(C) so designed and constructed that neces
the exits to the banking office.
sary services, repairs or inspections can readily be
made.
(2)
R obbery and burglary alarm systems, (i)
Robbery alarm systems. A robbery alarm system
Any camera used in such a system should be capable
should be provided for each banking office at which
o f taking at least one picture every 2 seconds and, if
the police ordinarily can arrive within 5 minutes af
it uses film, should contain enough unexposed film
ter an alarm is actuated; all other banking offices
at all times to be capable o f operating for not less
should be provid ed w ith ap p ropriate devices for
than 3 m in u te s, and the film should be at least
promptly notifying the police that a robbery has oc
16mm.
curred o r is in progress. Robbery alarm systems
should be:
(ii)
Installation and operation of surveillance
(A)
designed to transmit to the police, either
sy ste m s p ro v id in g s u r v e illa n c e o f oth e r than
directly or through an intermediary, a signal (not de
walk-up or drive-in teller’s stations or windows.
tectable by unauthorized persons) indicating that a
Surveillance devices for other than walk-up or drivecrime against the banking office has occurred or is
in teller’s stations or windows should be:
in progress;
For this Regulation to be complete as amended March 10. 1981. retain:
1) Regulation Pamphlet dated January 13, 1969.
2) This slip sheet. (Destroy slipsheet dated November I. 1973)
M A R C H 1981
(B) capable o f actuation by initiating devices
located at each te lle r’s station o r window (except
walk-up o r drive-in teller’s stations or windows in
which the teller is effectively protected by a bulletresistant barrier and effectively isolated from per
sons, other than fellow employees, inside a banking
office of which such station or window may be a
part);
(C) safeguarded against accidental transmis
sion of an alarm;
(D) equipped with a visual and audible sig
nal capable of indicating improper functioning of or
tampering with the system; and
(E) equipped with an independent source of
power (such as a battery) sufficient to assure contin
uously reliable operation o f the system for at least
24 hours in the event o f failure o f the usual source
of power.
(ii) B u r g la r y a la r m s y s te m s. A b u rg lary
alarm system should be provided for each banking
office. Burglary alarm systems should be:
(A) capable of detecting promptly an attack
on the outer door, walls, floor, or ceiling o f each
vault, and each safe not stored in a vault, in which
currency, negotiable securities, or similar valuables
are stored when the office is closed, and any attempt
to move any such safe;
(B) designed to transmit to the police, either
directly or through an intermediary, a signal indica
ting that any such attem pt is in progress; and for
banking offices at which the police ordinarily cannot
arrive within 5 minutes after an alarm is actuated,
designed to actuate a loud sounding bell or other de
vice that is audible inside the banking office and for
a distan ce o f approx im ately 500 feet outside the
banking office;
(C) safeguarded against accidental transmis
sion of an alarm;
(D) equipped with a visual and audible sig
nal capable of indicating improper functioning of or
tampering with the system; and
(E) equipped with an independent source of
power (such as a battery) sufficient to assure contin
uously reliable operation o f the system for at least
80 hours in the event o f failure of the usual source
of power.
(3)
W alk-up and drive-in teller’s stations or
windows. Walk-up and drive-in teller’s stations or
w indow s contracted for after February 15, 1969,
should be constructed in such a manner that tellers
are effectively protected by bullet-resistant barriers
from robbery or larceny by persons outside such sta
tions or windows. Such barriers should be of glass at
least 1-3/16 inches in thickness,1 or of material of at
1(Footnotes appear at end of Appendix A.)
least equivalent bullet-resistance. Pass-through de
vices should be so designed and constructed as not
to afford a person outside the station or window a
direct line o f fire at a person inside the station.
(4)
Vaults, safes, safe deposit boxes, night de
p ositories, and autom ated paying or receiving
m achines. V aults, safes (if not to be stored in a
vault), safe deposit boxes, night depositories, and
automated paying or receiving machines, in any of
w hich cu rrency, negotiable securities, or similar
valuables are to be stored when banking offices are
closed, should m eet o r exceed the standards e x
pressed in this section.
(i) V a u lts. A vault is defined as a room or
com partm ent that is designed for the storage and
safekeeping o f valuables and which has a size and
shape which permits entrance and movement within
by one or more persons. Other asset storage units
which do not meet this definition of a vault will be
considered as safes. Vaults contracted for after No
vember 1, 1973,2 should have walls, floor, and ceil
ing of reinforced concrete at least 12 inches in thick
n e s s.3 The vault door should be made of steel at
least 3'/2 inches in thickness, or other drill and torch
resistant material, and be equipped with a dial com
bination lock, a time lock, and a substantial lockable
daygate. Electrical conduits into the vault should not
exceed I {A inches in diameter and should be offset
within the walls, floor, or ceiling at least once so as
not to form a direct path of entry. A vault ventilator,
if provided, should be designed with consideration
of safety to life without significant reduction o f the
strength o f the vault wall to burglary attack. Alterna
tively, vaults should be so designed and constructed
as to afford at least equivalent burglary resistance.4
(ii) Safes. Safes contracted for after February
15, 1969, should weigh at least 750 pounds empty,
or be securely anchored to the premises where lo
cated. The body should consist o f steel, at least 1
inch in thickness, either cast or fabricated, with an
u ltim a te te n sile stren g th o f 5 0 ,0 0 0 p ou n d s per
square inch and be fastened in a manner equal to a
continuous 'A inch penetration weld having an ulti
mate tensile strength o f 50,000 pounds per square
inch. The door should be made o f steel that is at
least I'A inch in thickness, and at least equivalent in
strength to that specified for the body; and the door
should be equipped with a combination lock, or time
lock, and with a relocking device that will effec
tively lock the door if the combination lock or time
lock is punched. One hole not exceeding '/: inch di
ameter may be provided in the body to permit inser
tion of electrical conductors, but should be located
so as not to permit a direct view o f the door or lock
ing mechanism. Alternatively, safes should be con
structed o f materials that will afford at least equiva
lent burglary resistance.
(iii) Safe deposit boxes. Safe deposit boxes
used to safeguard customer valuables should be en
closed in a vault or safe meeting at least the above
specified minimum protection standards.
(iv) N ight d ep o sitories. N ight depositories
(excluding envelope drops not used to receive sub
stantial am ounts o f currency) contracted for after
February 15, 1969, should consist of a receptacle
chest having cast or welded steel walls, top, and
bottom, at least 1 inch in thickness; a steel door at
least l '/2 inches in thickness, with a combination
lock; and a chute, made o f steel that is at least 1
inch in thickness, securely bolted or welded to the
receptacle and to a depository entrance of strength
similar to the chute. Alternatively, night depositories
should be so designed and constructed as to afford at
least equivalent burglary resistance.5 Each deposi
tory en trance (oth er than an envelope drop slot)
should be equipped with a lock. Night depositories
should be equipped with a burglary alarm and be de
signed to protect against the “ fishing” of a deposit
from the deposit receptable, and to protect against
the “ trapping” o f a deposit for extraction.
characteristics as that o f a cash dispensing storage
chest and should be designed to protect against the
fishing and trapping of deposits. Necessary ventila
tion for the automated machines should be designed
so as to avoid significantly reducing the burglary re
sistance o f the machines. The cash dispensing ma
chine should also be designed so as to be protected
against actuation by unauthorized persons, should be
protected by a burglary alarm, and should be located
in a well-lighted area. Alternatively, cash dispensing
machines should be so designed and constructed as
to afford at least equivalent burglary resistan ce.6 A
cash dispen sin g m achine w hich is used inside a
bank’s premises only during bank business hours,
and which is empty of currency and coin at all other
tim es, should at least provide safeguards against
“ jim m y in g .” unauthorized opening of the storage
chest door, and against actuation by unauthorized
persons.
2.
Effective March 10, 1981, Section 216.3, Sec
tion 2 1 6 .4 and Section 216.5 are amended as set
forth below.
S E C T IO N 2 1 6 .3 — S EC U R ITY DEVICES
* *
(v) A u to m a te d p a y in g o r r e ce iv in g m a
chines. Except as hereinafter provided, cash dis
pensing machines (automated paying machines), in
cluding those machines which also accept deposits
(automated receiving machines) contracted for after
N o v e m b e r 1, 1973, sh o u ld w eigh at least 750
pounds empty, or be securely anchored to the prem
ises w h ere lo c ate d . C ash d isp e n sin g m a ch in e s
should co n tain , am ong o th er features, a storage
chest having cast o r welded steel walls, top, and
bottom, at least one inch in thickness, with a tensile
strength of at least 50,000 pounds per square inch.
Any doors should be constructed o f steel at least
equivalent in strength to the storage chest and be
equipped with a combination lock and with a relock
ing device that will effectively lock the door if the
combination lock is punched. The housing covering
the cash dispensing opening in the storage chest and
the housing covering the mechanism for removing
the cash from the storage chest, should be so d e
signed as to provide burglary resistance at least
equivalent to the storage chest and should also be
designed to protect against the “ fishing” o f cash
from the storage chest. The cash dispensing control
and delivering mechanism (and, when applicable,
cash deposit receipt mechanism) should be protected
by steel, at least '/> inch in thickness, securely at
tached to the storage chest. A cash dispensing ma
chine which also receives deposits should have a re
ceptacle chest having the same burglary resistant
* * *
(c) Implementation. It is appropriate for banking
offices in areas with a high incidence of crime to in
stall many devices which would not be practicable
because of costs for small banking offices in areas
substantially free of crimes against financial institu
tions. Each bank shall consider the appropriateness
of installing, maintaining, and operating security de
vices which are expected to give a general level of
bank protection at least equivalent to the standards
described in Appendix A of this Part, as amended.
In any case in which (on the basis o f the factors
listed in paragraph (b) or similar ones, the use of
other measures, or the decision that technological
change allows the use of other measures judged to
give equivalent protection) it is decided not to in
stall, maintain, and operate devices at least equiva
lent to these standards, the bank shall preserve in its
records a statement of the reasons for such decision.
SEC T IO N 2 1 6 .4 — S EC U R ITY PRO CED URES
(a)
Development and administration. On or be
fore July 15, 1969 (or within thirty days after a State
bank becomes a member of the Federal Reserve Sys
tem, whichever is later), each State member bank
shall develop and provide for the administration of a
security program to protect each o f its banking of
fices from robberies, burglaries, and larcenies and to
assist in the identification and apprehension of per
sons who commit such acts. This security program
shall be reduced to writing, approved by the bank’s
board of directors, and retained by the bank in such
form as will readily permit determination o f its ade
quacy and effectiveness.
* * * * *
Section 216.5 is amended by removing paragraph
(b), redesignating paragraph (c) as paragraph (b),
and redesignating paragraph (d) as paragraph (c), as
set forth below.
S EC T IO N 2 1 6 .5 — FILIN G O F REPORTS
* * * * *
(b) External crim e reports. Each time a rob
bery, burglary, or nonbank-employee larceny is per
petrated or attempted at a banking office operated by
a State member bank, the bank shall, within a rea
sonable time, file a report in conformity with the re
quirements of Form P-2. One copy of such report
shall be filed with the appropriate State supervisory
authority and three copies of such report shall be
filed with the Federal Reserve Bank for the District
in which the head office of the reporting bank is lo
cated.
(c) S pecial reports. Each State m em ber bank
shall file such other reports as the Board may require.
FOOTNOTES
1 It should be emphasized that this thickness is merely bulletresistant and not bulletproof.
2 Vaults contracted for previous to this date should be con
structed in conformance with all applicable specifications then in
effect.
3 The reinforced concrete should have: two grids of # 5 (-%" di
ameter) deformed steel bars located in horizontal and vertical rows
in each direction to form grids not more than 4 inches on center: or
two grids of expanded steel bank vault mesh placed parallel to the
face o f the walls, weighing at least 6 pounds per square foot to
each grid, having a diamond pattern not more than 3" x 8"; or two
grids of any other fabricated steel placed parallel to the face of the
walls, weighing at least 6 pounds per square foot to each grid and
having an open area not exceeding 4 inches on center. Grids are to
be located not less than 6 inches apart and staggered in each direc
tion. The concrete should develop an ultim ate com pression
strength of at least 3,000 pounds per square inch.
4 Equivalent burglary-resistant materials for vaults do not in
clude the use of a steel lining, either inside or outside a vault wall,
in lieu of the specified reinforcement and thickness of concrete.
Nonetheless, there may be instances, particularly where the con
struction of a vault of the specified reinforcement and thickness of
concrete would require substantial structural modification of an ex
isting building, where compliance with the specified standards
would be unreasonable in cost. In those instances, the bank should
comply with the procedure set forth in section 216.3(c) of Regula
tion P.
? Equivalent burglary-resistant materials for night depositories
include the use of one-fourth inch steel plate encased in 6 inches or
more of concrete or masonry building wall.
6 Equivalent burglary-resistant materials for cash dispensing ma
chines include the use of Vk inch thick nickel stainless steel meet
ing American Society o f Testing Materials <ASTM) Designation A
167-70, Type 304, in place of 1 inch thick steel, if other criteria
are satisfied.
@FedFRASER