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F E D E R A L R E S E R V E BANK O F N E W YORK r Circular No. 7 2 4 2 ~I U October 2, 1973 J MINIMUM STANDARDS FOR BANK SECURITY DEVICES Revised Appendix A to Regulation P To All State Hem'ber Banks, and Others Concerned, in the Second Federal Reserve District: The following statement was issued October 1 by the Board o f Governors o f the Federal Reserve System : The Board of Governors o f the Federal Reserve System today announced revisions of its Regulation P to strengthen implementation of the Bank Protection Act. The revisions, effective November 1, 1973, are largely technical and clarify minimum standards to be met by State member banks regarding the installation, maintenance and operation of security devices, with the double aim of discouraging crimes against financial institutions and assisting the apprehension of perpetrators of such crimes. They include a definition of requirements for vaults as distinguished from safes, protection standards for cash dispensing machines and a clarification of the rules that safe deposit boxes be stored in an approved vault or safe. Under Regulation P, if a bank decides not to install, maintain or operate devices to meet the minimum standards for bank security, as defined in Appendix A of the Regulation, it is required to forward to the Reserve Bank in its district a statement of reasons for its decision. The revisions are similar to the regulatory change proposed for comment by the Federal Reserve, the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Federal Home Loan Bank Board last January. Since then, the four regulatory agencies, through the Interagency Coordinating Committee, have considered public comment and have observed demonstrations of security devices by industry representatives and the Federal Bureau of Investi gation. The Interagency Committee has unanimously approved the proposed revisions. Enclosed is a copy o f Appendix A, “ Minimum Standards for Security Devices,” Revised effective November 1, 1973, to Regulation P, which reflects the above changes. Additional copies of the enclosure will be furnished upon request. A lfred H a ye s, President. BOARD O F GOVERNORS OF THE FEDERAL RESERVE SYSTEM APPENDIX A TO REGULATION P Revised effective November 1, 1973 Minimum Standards for Security Devices In order to assure realization of maximum performance capabilities, all security devices utilized by a bank should be regularly in spected, tested, and serviced by competent persons. Actuating devices for surveillance systems and robbery alarms should be oper able with the least risk of detection by un authorized persons that can be practicably achieved. (1) Surveillance systems, (i) General. Sur veillance systems should be: (A ) equipped with one or more photo graphic, recording, monitoring, or like de vices capable of reproducing images of per sons in the banking office with sufficient clarity to facilitate (through photographs capable of being enlarged to produce a oneinch vertical head-size of persons whose images have been reproduced) the identification and apprehension of robbers or other suspicious persons; (B) reasonably silent in operation; and (C ) so designed and constructed that nec essary 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 capa ble of operating for not less than 3 minutes, and the film should be at least 16mm. (ii) Installation and operation of surveil lance systems providing surveillance of other than walk-up or drive-in teller’s stations or windows. Surveillance devices for other than walk-up or drive-in teller's stations or win dows should b e : (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 station or window; and (B) capable of actuation by initiating de vices located at each teller’s station or window. (iii) Installation and operation of surveil lance systems providing surveillance of walkup or drive-in teller’s stations or windows. Surveillance 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 position to transact business at each such station or window and areas of such station or window that are vul nerable to robbery or larceny. Such devices should be capable of actuation by one or more initiating devices located within or in close proximity to such station or window. Such devices may be omitted in the case of a walkup or drive-in teller’s station or window in which the teller is effectively protected by a bullet-resistant barrier from persons outside the station or window. However, if the teller is vulnerable to larceny or robbery by mem bers of the public who enter the banking office, the teller should have access to a device to actuate a surveillance system that covers the area of vulnerability or the exits to the bank ing 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 after an alarm is actuated; all other banking offices should be provided with appropriate devices for promptly notify ing the police that a robbery has occurred 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 detectable by unauthorized per sons) indicating that a crime against the banking office has occurred or is in progress; (B ) capable of actuation by initiating de vices located at each teller’s station or window PRINTED IN NEW YORK (except walk-up or drive-in teller’s stations or windows in which the teller is effectively protected by a bullet-resistant barrier and effectively isolated from persons, other than fellow employees, inside a banking office of which such station or window may be a part) ; (C ) safeguarded against accidental trans mission of an alarm; (D ) equipped with a visual and audible signal capable of indicating improper func tioning of or tampering with the system; and (E ) equipped with an independent source of power (such as a battery) sufficient to assure continuously reliable operation of the system for at least 24 hours in the event of failure of the usual source of power. (ii) Burglary alarm systems. A burglary alarm system should be provided for each banking office. Burglary alarm systems should be: (A ) capable of detecting promptly an at tack 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 indicating that any such attempt is in progress; and for banking offices at which the police ordinarily cannot arrive within 5 min utes after an alarm is actuated, designed to actuate a loud sounding bell or other device that is audible inside the banking office and for a distance of approximately 500 feet out side the banking office; (C ) safeguarded against accidental trans mission of an alarm; (D ) equipped with a visual and audible signal capable of indicating improper func tioning of or tampering with the system; and (E ) equipped with an independent source of power (such as a battery) sufficient to assure continuously reliable operation of the system for at least 80 hours in the event of failure of the usual source of power. (3) Walk-up and drive-in teller’s stations or windows. Walk-up and drive-in teller’s stations or windows contracted for after Feb ruary 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 stations or windows. Such barriers should be of glass at least 1%6 inches in thickness,1 or of material of at least equivalent bullet-resistance. Pass through devices 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 depositories, and automated paying or receiv ing machines. Vaults, safes (if not to be stored in a vault), safe deposit boxes, night depositories, and automated paying or receiv ing machines, in any of which currency, nego tiable securities, or similar valuables are to be stored when banking offices are closed, should meet or exceed the standards expressed in this section. (i) Vaults. A vault is defined as a room or 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 November 1, 1973,2 should have walls, floor, and ceiling of reinforced concrete at least 12 inches in thickness.3 The vault door should be made of 1 It should be emphasized that this thickness is merely bullet-resistant and not bulletproof. - 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 (5ij" diameter) deformed steel bars located in horizontal and vertical rows in each direction to form grids net more than 4 inches on center; or two grids of expanded steel bank vault mesh placed parallel to the face of 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 direction. The concrete should develop an ultimate compression strength of at least 3,000 pounds per square inch. steel at least 3y 2 inches in thickness, or other drill and torch resistant material, and be equipped with a dial combination lock, a time lock, and a substantial lockable day-gate. Electrical conduits into the vault should not exceed IV2 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 de signed 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 con structed as to afford at least equivalent bur glary resistance.4 (ii) Safes. Safes contracted for after Feb ruary 15, 1969, should weigh at least 750 pounds empty, or be securely anchored to the premises 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 inch penetration weld having an ultimate tensile strength of 50,000 pounds per square inch. The door should be made of steel that is at least l 1/^ inch in thickness, and at least equivalent in strength to that speci fied for the b od y ; and the door should be equipped with a combination lock, or time lock, and with a relocking device that will effectively lock the door if the combination lock or time lock is punched. One hole not ex ceeding V2 inch diameter may be provided in the body to permit insertion of electrical con ductors, but should be located so as not to permit a direct view of the door or locking mechanism. Alternatively, safes should be constructed of materials that will afford at least equivalent burglary resistance. (iii) Safe deposit boxes. Safe deposit boxes used to safeguard customer valuables should 4 Equivalent burglary-resistant materials for vaults do not include 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 construction of a vault of the specified reinforcement and thickness of concrete would require sub stantial structural modification of an existing building, where compliance with the specified standards would be unreasonable in cost. I 11 those instances, the bank should comply with the procedure set forth in section 216.3(c) of Regulation P. be enclosed in a vault or safe meeting at least the above-specified minimum protection standards. (iv) Night depositories. Night depositories (excluding envelope drops not used to receive substantial 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 thick ness; a steel door at least IVo inches in thick ness, with a combination lock ; and a chute, made of steel that is at least 1 inch in thick ness, securely bolted or welded to the recep tacle and to a depository entrance of strength similar to the chute. Alternatively, night de positories should be so designed and construc ted as to afford at least equivalent burglary re sistance.5 Each depository entrance (other than an envelope drop slot) should be equipped with a lock. Night depositories should be equipped with a burglar alarm and be de signed to protect against the “ fishing” of a deposit from the deposit receptacle, and to protect against the “ trapping” of a deposit for extraction. (v) Automated paying or receiving ma chines. Except as hereinafter provided, cash dispensing machines (automated paying ma chines), including those machines which also accept deposits (automated receiving ma chines) contracted for after November 1, 1973, should weigh at least 750 pounds empty, or be securely anchored to the premises where located. Cash dispensing machines should contain, among other features, a storage cliest having cast or 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 of steel at least equivalent in strength to the storage chest and be equipped with a com bination lock and with a relocking device that will effectively lock the door if the combina tion 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, 5 Equivalent burglary-resistant materials for night deposi tories include the use of one-fourth inch steel plate encased in 6 inches or more of concrete or masonry building wall. should be so designed as to provide burglary resistance at least equivalent to the storage chest and should also be designed to protect against the ‘ ‘ fishing ’ ’ of cash from the storage chest. The cash dispensing control and deliv ering mechanism (and, when applicable, cash deposit receipt mechanism) should be pro tected by steel, at least 1/2 inch in thickness, securely attached to the storage chest. A cash dispensing machine which also receives depos its should have a receptacle chest having the same burglary resistant characteristics as that of a cash dispensing storage chest and should be designed to protect against the fishing and trapping of deposits. Necessary ventilation for the automated machines should be designed so as to avoid significantly reducing the bur glary resistance of the machines. The cash dispensing machine should also be designed so as to be protected against actuation by un authorized persons, should be protected by a burglar alarm, and should be located in a well-lighted area. Alternatively, cash dispens ing machines should be so designed and con structed as to afford at least equivalent bur glary resistance.6 A cash dispensing machine which is used inside a bank’s premises only during bank business hours, and which is empty of currency and coin at all other times, should at least provide safeguards against “ jimmying,” unauthorized opening of the storage chest door, and against actuation by unauthorized persons. 0 Equivalent burglary-resistant materials for cash dispens ing machines 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.
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