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F ed er a l Reser ve Ba n k

of

Dallas

DALLAS. TEXAS 75222
Circular No. 81-241
December 23, 1981

AMENDMENT TO REGULATION P
Report of Crime

TO ALL STATE MEMBER BANKS
AND OTHERS CONCERNED IN THE
ELEVENTH FEDERAL RESERVE DISTRICT:
The Board of Governors of the Federal Reserve System has
amended, effective October 6, 1981, its Regulation P, "Minimum Security
Devices and Procedures for Federal Reserve Banks and State Member Banks",
to eliminate the External Crime Reports required under regulations im­
plementing the Bank Protection Act.
Enclosed is a copy of the amendment in slip-sheet form which
should be filed in Vol. n of your Regulations Binders. For your regulation to
be complete as amended October 6, 1981, you should retain the Regulation
Pamphlet dated January 13, 1969, this slip-sheet and destroy slip-sheet dated
March 1981.
If you have questions regarding this amendment, please contact
Helen Calvert of the Bank Supervision and Regulations Department, Extension
6663.
Additional copies of the circular and amendment will be furnished
upon request to the Department of Communications, Financial and Community
Affairs of this Bank, Extension 6289.
Sincerely yours,

William H. Wallace
First Vice President
Enclosure

Banks and others are encouraged to use the following incoming W ATS 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)

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

MINIMUM SECURITY DEVICES AND PROCEDURES
FOR FEDERAL RESERVE BANKS AND STATE MEMBER BANKS
AMENDMENTS TO REGULATION P t
As amended effective October 6, 1981
Effective M arch 10, 1981, Section 216.3(c) is
amended as set forth below:
SECTION 216.3— SECURITY DEVICES
*

*

*

*

*

(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 of 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.

.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 of its ade­
quacy and effectiveness.
*

*

*

*

*

E ffective M arch 10, 1981, Section 216.S is
amended by removing paragraph (b), redesignating
paragraph (c) as paragraph (b), and redesignating
paragraph (d) as paragraph (c); and effective Octo­
ber 6, 1981, paragraph (b) was revised to read as
follows:
SECTION 216.5— FILING O F REPORTS

(b) Records o f external crime. After a robbery,
burglary or nonemployee larceny is committed or at­
tempted at a banking office of a State member bank,
the bank shall keep a record o f the incident at its
main office. The record may be a copy of a police,
insurance or similar report of the incident. Alterna­
tively, the bank may wish to develop its own record
Effective M arch 10, 1981, Section 216.4(a) is
indicating the office at which the incident occurred,
amended to read as follows:
the type of crime, when the crime occurred and the
amount of any loss; whether operational or mechani­
SECTION 216.4— SECURITY PROCEDURES
cal deficiencies might have contributed to the crime;
and what has been or will be done to correct any de­
(a)
Development and administration. On or be­ ficiencies.
fore July IS, 1969 (or within thirty days after a State
(c) Special reports. Each State member bank
bank becomes a member of the Federal Reserve Sys­
shall file such other reports as the Board may re­
tem, whichever is later), each State member bank
quire.
shall develop and provide for the administration of a
security program to protect each o f its banking of­
Effective November 1, 1973, Appendix A of Reg­
fices from robberies, burglaries, and larcenies and to
ulation P is amended to read as follows:

t For this Regulation to be complete at amended October 6, 1981 retain:
1) Regulation Pamphlet dated January 13, 1969.
2) This slip sheet. (Destroy slip sheet dated March 1981).

NOVEMBER 1981

APPENDIX A
M INIM UM STANDARDS FOR
SECURITY DEVICES
In order to assure realization of maximum perfor­
mance capabilities, all security devices utilized by a
bank should be regularly inspected, tested, and serv­
iced by competent persons. Actuating devices for
surveillance systems and robbery alarms should be
operable with the least risk of detection by unauthor­
ized persons that can be practicably achieved.
(1)
Surveillance systems, (i) General. Surveil­
lance systems should be:
(A) equipped with one or m ore p h oto­
graphic, recording, monitoring, or like devices capa­
ble of reproducing images of persons in the banking
office with sufficient clarity to facilitate (through
photographs capable of being enlarged to produce a
one-inch vertical head-size of persons whose images
have been reproduced) the identification and appre­
hension of robbers or other suspicious persons;
(B) reasonably silent in operation; and
(C) so designed and constructed that neces­
sary services, repairs or inspections can readily be
made.
Any camera used in such a system should be capable
of taking at least one picture every 2 seconds and, if
it uses film, should contain enough unexposed film
at all times to be capable of operating for not less
than 3 m inutes, and the film should be at least
16mm.
(ii) Installation and operation of surveillance
system s providing surveillance o f other than
walk-up or drive-in teller’s stations or windows.
Surveillance devices for other than walk-up or drivein teller’s stations or windows should be:
(A) located so as to reproduce identifiable
images of persons either leaving the banking office
or in a position to transact business at each such sta­
tion or window; and
(B) capable of actuation by initiating devices
located at each teller’s station or window.
(iii) Installation and operation o f surveil­
lance systems providing surveillance of walk-up
or drive-in teller’s stations or windows. Surveil­
lance devices for walk-up or drive-in teller’s stations
or windows should be located in such a manner as to
reproduce identifiable images of persons in a posi­
tion to transact business at each such station or win­
dow and areas of such station or window that are
vulnerable to robbery or larceny. Such devices
should be capable of actuation by one or more initi­
ating devices located within or in close proximity to

such station or window. Such devices may be omit­
ted in the case of a walk-up or drive-in teller’s sta­
tion or window in which the teller is effectively pro­
tected by a bullet-resistant barrier from persons
outside the station or window. However, if the teller
is vulnerable to larceny or robbery by members of
the public who enter the banking office, the teller
should have access to a device to actuate a surveil­
lance system that covers the area of vulnerability or
the exits to the banking office.
(2)
Robbery and burglary alarm systems, (i)
Robbery alarm systems. A robbery alarm system
should be provided for each banking office at which
the police ordinarily can arrive within 5 minutes af­
ter an alarm is actuated; all other banking offices
should be provided with appropriate devices for
promptly notifying the police that a robbery has oc­
curred or is in progress. Robbery alarm systems
should be:
(A) designed to transmit to the police, either
directly or through an intermediary, a signal (not de­
tectable by unauthorized persons) indicating that a
crime against the banking office has occurred or is
in progress;
(B) capable of actuation by initiating devices
located at each teller’s station or window (except
walk-up or 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 of the system for at least
24 hours in the event of failure of the usual source
of power.
(ii)
Burglary alarm system s. A burglary
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 of 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 attempt 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 distance o f approxim 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 of the system for at least
80 hours in the event of failure of the usual source
of power.
(3) W alk-up an d drive-in te lle r’s stations or
windows. Walk-up and drive-in teller’s stations or
windows 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 P/i6 inches in thickness,' or of material of at
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 of fire at a person inside the station.
(4) Vaults, safes, safe deposit boxes, night de­
p o sito ries, an d a u to m ated p aying o r 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
which currency, negotiable securities, or similar
valuables are to be stored when banking offices are
closed, should meet or exceed the standards ex­
pressed in this section.
(i)
V a u lts. A vault is defined as a room
compartment that is designed for the storage and
safekeeping of 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
ness.5 The vault door should be made of steel at least

' It should be emphasized that this thickness is m erely bulletresistani and not bulletproof.
2 Vaults contracted for previous to this date should be constructed in
conformance with all applicable specifications then in effect.
3 The reinforced concrete should have: two grids of # 5 (%* diame­
ter) 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 o f any other fab­
ricated 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 ex-

3'/2 inches in thickness, or other drill and torch re­
sistant material, and be equipped with a dial combi­
nation lock, a time lock, and a substantial lockable
daygate. Electrical conduits into the vault should not
exceed 1V2 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 of the
strength of 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 Febru­
ary 15, 1969, should weigh at least 750 pounds
em pty, or be securely anchored to the prem ises
where located. The body should consist of steel, at
least 1 inch in thickness, either cast or fabricated,
with an ultimate tensile strength of 50,000 pounds
per square inch and be fastened in a manner equal to
a continuous 'A inch penetration weld having an ulti­
mate tensile strength of 50,000 pounds per square
inch. The door should be made o f steel that is at
least l '/2 inches 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 ef­
fectively lock the door if the combination lock or
time lock is punched. One hole not exceeding V2
inch diameter may be provided in the body to permit
insertion of electrical conductors, but should be lo­
cated so as not to permit a direct view of the door or
locking mechanism. Alternatively, safes should be
constructed of m aterials that will afford at least
equivalent burglary resistance.
(iii) Safe deposit boxes. Safe deposit boxes
used to safeguard customer valuables should be en­
orclosed in a vault or safe meeting at least the above­
specified minimum protection standards.
(iv) N ight d ep o sito ries. Night depositories
(excluding envelope drops not used to receive sub­
stantial amounts of 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 IV2 inches in thickness, with a combination
lock; and a chute, made of steel that is at least 1
ceeding 4 inches on center. Grids are to be located not less than 6
inches apart and staggered in each direction. The concrete should de­
velop an ultimate compression strength of at least 3,000 pounds per
square inch.
4 Equivalent burglary-resistant materials for vaults do not include the
use of a steel lining, either inside or outside a vault wail, in lieu of the
specified reinforcement and thickness of concrete. Nonetheless, there
may be instances, particularly where the construction o f a vault o f the
specified reinforcement and thickness of concrete would require sub­
stantial structural modification o f an existing building, where com­
pliance with the specified standards would be unreasonable in costr In
those instances, the bank should comply with the procedure set forth in
section 216.3(c) of Regulation P.

signed as to provide burglary resistance at least
inch in thickness, securely bolted or welded to the
equivalent to the storage chest and should also be
receptacle and to a depository entrance of strength
designed to protect against the “ fishing” of cash
similar to the chute. Alternatively, night depositories
from the storage chest. The cash dispensing control
should be so designed and constructed as to afford at
and delivering mechanism (and, when applicable,
least equivalent burglary resistance.9 Each deposi­
cash deposit receipt mechanism) should be protected
tory entrance (other than an envelope drop slot)
by steel, at least V2 inch in thickness, securely at­
should be equipped with a lock. Night depositories
tached to the storage chest. A cash dispensing ma­
should be equipped with a burglary alarm and be de­
chine which also receives deposits should have a re­
signed to protect against the “ fishing” of a deposit
ceptacle chest having the same burglary resistant
from the deposit receptacle, and to protect against
characteristics as that of a cash dispensing storage
the “ trapping” of a deposit for extraction.
(v)
A utom ated paying or receivin g m a­chest and should be designed to protect against the
fishing and trapping of deposits. Necessary ventila­
chines. Except as hereinafter provided, cash dis­
tion for the automated machines should be designed
pensing machines (automated paying machines), in­
so as to avoid significantly reducing the burglary re­
cluding those machines which also accept deposits
sistance of the machines. The cash dispensing ma­
(automated receiving machines) contracted for after
chine should also be designed so as to be protected
N ovem ber 1, 1973, should w eigh at least 750
against actuation by unauthorized persons, should be
pounds empty, or be securely anchored to the prem­
protected by a burglary alarm, and should be located
ises where located. C ash dispensing m achines
in a well-lighted area. Alternatively, cash dispensing
should contain, among other features, a storage
machines should be so designed and constructed as
chest having cast or welded steel w alls, top, and
to afford at least equivalent burglary resistance.6 A
bottom, at least 1 inch in thickness, with a tensile
cash dispensing m achine which is used inside a
strength of at least 50,000 pounds per square inch.
bank’s premises only during bank business hours,
Any doors should be constructed of steel at least
and which is empty of currency and coin at all other
equivalent in strength to the storage chest and be
times, should at least provide safeguards against
equipped with a combination lock and with a relock­
“ jim m ying,” unauthorized opening of the storage
ing device that will effectively lock the door if the
chest door, and against actuation by unauthorized
combination lock is punched. The housing covering
persons.
the cash dispensing opening in the storage chest and
the housing covering the mechanism for removing
the case from the storage chest, should be so de5 Equivalent burglary*resistant materials for night depositories in­
clude 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 % inch thick nickel stainless steel meeting
American Society of Testing Materials (ASTM) Designation A 167- 70 .
Type 304, in place of 1 inch thick steel, if other criteria are satisfied.