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Ai* £?«rcu l<\r- tOo. 7079 FED ER A L RESERVE BANK O F N E W YORK January 9, 1973 STRENGTHENED IMPLEMENTATION OF BANK PROTECTION ACT To All State Member Banks, and Others Concerned, in the Second Federal Reserve District: The following statement was issued January 3 by the Board o f Governors o f the Federal Reserve System: The Board of Governors o f the Federal Reserve System took two steps today to strengthen its implementation o f the Bank Protection Act which is designed to discourage crimes against financial institutions and to help apprehend the perpetrators of such crimes. The Board issued for comment, simultaneously with the Comptroller of the Currency, Federal Deposit Insurance Corporation, and the Federal Home Loan Bank Board, a proposed amendment to bring its Bank Protection Act regulation (Regulation P) up to date. Comment should be received by February 2. At the same time the Board initiated a campaign to encourage State member banks to install security devices in high crime areas and in offices which have experienced one or more robberies since the regulation went into effect in early 1969. Statistics compiled by the Department of Justice indicate a continued high level of bank robberies — as distinguished from burglaries and larcenies — although the rate o f increase appears to have slowed, possibly as a result o f implementation o f the Bank Protection Act and security measures taken by the banking industry. The Department reported that during the year which ended June 30, 1972, there were 2,600 bank robberies, 360 burglaries, and 212 larcenies for a total o f 3,172 offenses. This compares with 2,565 robberies, 471 burglaries and 318 larcenies for a total of 3,354 offenses during the year which ended June 30, 1971. In instructions to the Federal Reserve Banks, the Board has expressed concern “ that the seriousness of the extent of crimes against banks has not abated since enactment o f the Bank Protection Act and, in view o f the deficiencies noted in security programs o f banks which have experienced external crimes in recent months, believes that additional action should be taken to assure that all State members are in compliance with the Bank Protection Act regulation.” The proposal issued today would bring the security standards in Appendix A to Regulation P up to date in light o f developments over the past several years. Under the Regulation, if a bank decides not to install, maintain or operate the devices to meet the minimum standards defined in Appendix A, it is required to forward to the Reserve Bank in its district a statement of the reasons for its decision. National banks and Federally insured State nonmember banks are subject to similar regulations issued by the Comptroller of the Currency and the Federal Deposit Insurance Corporation, respectively, which require the preservation in the bank’s own records a statement o f the reasons for its decision. The Reserve Banks were asked to review their files and determine: (a) which banks have reported security deficiencies on forms they have filed since January 1, 1970, and which banks have been cited in examination reports as deficient. (b) which banks were robbed or burglarized during the same period and have a statement on file indicating that security devices have not been installed. The Reserve Banks were also asked to contact deficient banks to determine whether corrections have been made and, if not, what plans management has for making corrections. Statements filed by banks that have been robbed or burglarized are to be reviewed to determine whether the reasons cited for not installing security devices are still valid. In cases where it appears that the bank should now have additional security, contact is to be made to emphasize the need for the installation and to obtain a commitment from the bank to do so. In conclusion, the Board stated: “ The Board is o f the opinion that, except in extraordinary circumstances, a bank can no longer justify not installing security devices after it has been robbed, and that the Reserve Bank should insist on affirma tive action such as the installation of the necessary number o f cameras in all offices which have experienced one or more robberies.” A pilot survey of a high crime area recently conducted by the Federal supervisory authorities indicated that approximately 95 per cent of the banking offices surveyed had some form of surveillance system and alarms and that about 80 per cent o f the suspects apprehended on bank robbery charges in 1971 is directly attributable to bank security devices. Comment on the proposed revision o f Appendix A to Regulation P should be submitted to the Board. The proposed revision would: 1. Distinguish between requirements for vaults and safes to eliminate confusion. 2. Make clear that safe deposit boxes must be contained in an approved vault or safe. 3. Permit use o f reinforced concrete at least 12 inches thick in vault construction (the 5R specifications of the National Insurance Rating Board), a specification which provides burglary resistance equivalent to 18 inches o f concrete under the original minimum standard. 4. Prohibit the use of steel in lieu of concrete for vault walls or wall liners. 5. Permit alarm companies to drill slightly larger holes in safes for inserting cables now required for some modern, improved systems. 6. Prescribe protection standards for cash dispensing machines. Printed below is an excerpt from the Federal R egister o f January 3, containing the text o f the proposed amendment to Regulation P. Comments thereon should be submitted by February 2 and may be sent to our Regulations and Bank Analysis Department. Alfred Hayes, President. FEDERAL RESERVE SYSTEM I 12 CFR Part 216 1 [Reg. P] FEDERAL RESERVE BANKS A N D STATE M EM BER BANKS M inim um Security Devices and Procedures Notice Is hereby given that the Board of Governors of the Federal Reserve Sys tem proposes to revise appendix A, "M ini mum Standards for Security Devices,” of Part 216 entitled “Minimum Security Devices and Procedures for Federal Re serve Banks and State Member Banks.” As part of its responsibilities under the Bank Protection Act of 1968 (82 Stat. 294), the Board of Governors conducts a continuing review of the minimum stand ards for bank security devices. Based on its review, the proposed appendix A re vises and clarifies the minimum stand ards with which each Federal Reserve bank and each State member bank must comply with respect to the installation, maintenance, and operation of security devices to discourage robberies, bur glaries, and larcenies and to assist in the identification and apprehension of per sons who commit such acts. Among the proposed revisions are a definition of vaults as distinguished from safes, modified standards of vault con struction, and protection standards for cash dispensing machines. The proposed revision also makes clear that, to meet the minimum security standards, safe deposit boxes must be stored in an ap proved vault or safe. The proposed revisions would be ac complished by amending appendix A to read as follows: A M IN IM U M p p e n d ix STANDARDS TOR A SE C U R IT Y 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. Surveillance 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 1-lnch vertical head-size of persons whose images have been reproduced) the identmcatlon and apprehension of robbers or other suspicious persons; (B) Reasonably silent In operation; and (C) So designed and constructed that ties, or similar valuables are stored when the necessary services, repairs or inspections can office is closed, and any attempt to move any readily be made. Any camera used in such a system should such safe; be capable of taking at least one picture (B) Designed to transmit to the police, every 2 seconds and, If it uses film, should either directly or through an intermediary, a contain enough unexposed film at all times signal indicating that any such attempt is in to be capable of operating for not lees than progress; and for banking offices at which the 3 minutes, and the film should be at least police ordinarily cannot arrive within five minutes after an alarm is actuated, designed 16mm. (ii) Installation and operation of surveil to actuate a loud-sounding bell or other de lance system s providing surveillance of other vice that is audible inside the banking office than walkup or drive-in teller’s stations or and for a distance of approximately 500 feet windows. Surveillance devices for other than outside the banking office; walkup or drlve-in teller’s stations or win (C) Safeguarded against accidental trans mission of an alarm; dows should be: (A) Located so as to reproduce identifiable (D) Equipped with a visual and audible Images of persons either leaving the banking signal capable of indicating improper func office or in a position to transact business at tioning of or tampering with the system; and each such station or window; and (E) Equipped with an independent source (B) Capable of actuation by initiating de of power (such as a battery) sufficient to as vices located at each teller’s station or sure continuously reliable operation of the window. system for at least 80 hours in the event of (iii) Installation and operation of surveil failure of the usual source of power. lance system s providing surveillance of (3) Walk-up and drive-in teller’s stations walkup or drive-in teller’s stations or win or windows. W alk-up and drlve-in teller’s sta dows. Surveillance devices for walkup or tions or windows contracted for after Febru drive-in teller's stations or windows should ary 15, 1969, should be constructed In such a be located in such a manner as to reproduce manner that tellers are effectively protected Identifiable images of persons in a position by bullet-resistant barriers from robbery or to transact business at each such station or larceny by persons outside such stations or window and areas of such station or window windows. Such barriers should be of glass at that are vulnerable to robbery or larceny. least 1%6 inches In thicknesses,1 or of m a Such devices should be capable of actuation terial of at least equivalent bullet resistance. by one or more initiating devices located Pass-through devices should be so designed within, or In close proximity to, such sta and constructed as not to afford a person out tion or window. Such devices may be omitted side the station or window a direct line of fire In the case of a walkup or drive-in teller’s at a person inside the station. station or window in which the teller Is ef (4) Vaults, safes, safe-deposit boxes, night fectively protected by a bullet-resistant bar depositories, and cash dispensing machines. rier from persons outside the station or win Vaults, safes (if not to be stored in a vault), dow. However, if the teller is vulnerable to safe-deposit boxes, night depositories, and larceny or robbery by members of the public cash dispensing machines, in any of which who enter the banking office, the teller currency, negotiable securities, or similar val should have access to a device to actuate a uables are to be stored when banking offices surveillance system that covers the area of are closed, should meet or exceed the stand vulnerability of the exits to the banking ards expressed In this section. office (1) Vaults. A vault Is defined as a room or (2) Robbery and bulglary alarm systems— compartment that is designed for the storage (1) Robbery alarm systems. A robbery alarm and safekeeping of valuables and which has system should be provided for each banking a size and shape which permits entrance and office at which the police ordinarily can ar movement within by one or more persons. rive within 5 minutes after an alarm Is actu Vaults contracted for after [effective date to ated; all other banking offices should be pro be designated] 2 should have walls, fioof, and vided with appropriate devices for promptly ceiling of reinforced concrete at least 12 notifying the police that a robbery has oc Inches In thickness* The vault door should curred or is In progress. Robbery alarm sys be made of steel at least 3 y2 inches In thick tems should be: ness, or other drill and torch resistant m a (A) Designed to transmit to the police, terial, and be equipped with dual combina either directly or through an Intermediary, tion locks, a timelock, and a substantial locka signal (not detectable by unauthorized able daygate. Electrical conduits into the persons) Indicating that a crime against the vault should not exceed 1 y2 inches In di banking office has occurred or is in progress; ameter and should be offset within the walls, (B) Capable of actuation by initiating de floor, or celling at least once so as not to form vices located at each teller’s station or win a direct path of entry. A vault ventilator, if dow (except walkup or drlve-in teller’s sta tions or windows in which the teller is ef 1 It should be emphasized that this thick fectively protected by a bullet-resistant bar ness is merely bullet resistant and not bullet rier and effectively isolated from persons, proof. other than fellow employees, inside a bank ing office of which such station or window 2 Vaults contracted for previous to this date may be a p a rt); should be constructed in conformance with (C) Safeguarded against accidental trans all applicable specifications then in effect. mission of an alarm; 3 The reinforced concrete should have: two (D) Equipped with a visual and audible grids of No. 5 (% inch diameter) deformed signal capable of Indicating improper func steel bars located in horizontal and vertical tioning of or tampering with the system; rows in each direction to form grids not more and than 4 inches on center; or two grids of ex (E) Equipped with an independent source panded steel bank vault mesh placed parallel of power (such as a battery) sufficient to as to the face of the walls, weighing at least 6 sure continuously reliable operation of the pounds per square foot to each grid, having a system for at least 24 hours In the event of diamond pattern not more than 3 ” x 8” ; or failure of the usual source of power. two grids of any other fabricated steel placed (11) Burglary alarm systems. A burglary parallel to the face of the walls, weighing at alarm system should be provided for each least 6 pounds per square foot to each grid banking office. Burglary alarm systems should and having an open area not exceeding 4 be: inches on center. Grids are to be located not (A) Capable of detecting promptly an at less than 6 Inches apart and staggered in tack on the outer door, walls, floor, or ceiling each direction. The concrete should develop of each vault, and each safe not stored in a an ultimate compression strength of at least vault, in which currency, negotiable securi 3,000 pounds per square inch. provided, should be designed with considera tion of safety to life without significant re duction of the strexigth of the vault wall to burglary attack. Alternatively, vaults should be so designed and constructed as to afford at least equivalent burglary resistance.4 (ii) Safes. Safes contracted for after Feb ruary 15, 1969, should weigh at least 750 pounds empty, or be secured anchored to the premises were 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 yA-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 1 y2 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, and with a relocking device that will effectively lock the door if the combination lock is punched. One hole not exceeding y2 -inch diameter may be provided in the body to permit Insertion of electrical conductors, but should be located so as not to permit a direct view of the door or locking mechanism. A l ternatively, 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 be enclosed in a vault or safe meeting at least the above-specified minim um 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 thickness; a steel door at least 1 y2 Inches in thickness with a combination lock; and a chute, made of 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 The depository entrance should be equipped with a lock. Night de positories should be equipped with a burglar alarm and be designed to protect against the “fishing” of a deposit from the deposit re ceptacle, and to protect against the “ trap ping” of a deposit for extraction. (v) Cash dispensing machines. Except as hereinafter provided, cash dispensing m a chines (including those machines which also accept deposits) contracted for after [effec tive date to be designated] should weigh at least 750 pounds empty, or be securely an chored to the premises where located. These machines should contain, among other fea tures, a storage chest having cast or welded steel walls, top, and bottom, at least 1 Inch in thickness, with a tensile strength of at least 50,000 pounds per square inch. The door should be construct ed of steel at least equiv alent in strength to the storage chest and be equipped with a combination lock and with a relocking device that will effectively lock the door if the combination lock is punched. The housing covering the cash dispensing opening (and, when applicable, deposit re ceiving opening) in the storage chest, and the housing covering the mechanism for re moving the cash from the storage chest. * Equivalent burglary-resistant materials for vaults do not include the use of steel lining, either inside or outside a vault wall, in lieu of the specified reinforcement and thtckness of concrete. c Equivalent burglary-resistant materials for night depositories include the use of yAinch 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 de livery mechanisms (and, when applicable, cash deposit receipt mechanism) should be protected by steel, at least y2-inch in thick ness, securely attached to the storage chest. The cash dispensing machine should be de signed so as to be protected against actua tion by unauthorized persons, should be pro tected by a burglar alarm, and should be located in a well-lighted area. Alternatively, cash dispensing machines should be so de signed and constructed as to afford at least equivalent burglary resistance." « Equivalent burglary-resistant materials for cash dispensing machines include the use of % -in ch thick 8 percent nickel stainless steel alloy in place of 1-inch thick steel, if other criteria are satisfied. A cash dispensing machine which is used inside a bank’s premises only during bank business hours, and which is empty of cur rency 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. This notice is published pursuant to section 553 of title 5, United States Code and § 262.2(a) of the rules of procedures of the Board of Governors of the Federal Reserve System. To aid in the consideration of the pro posed revision by the Board, interested persons are invited to submit relevant data, views, or arguments. Any such comments or material should be sub mitted in writing to the Secretary, Board of Governors of the Federal Reserve Sys tem, Washington, D.C. 20551, to be re ceived not later than 30 days from the date of publication of this notice in the F ederal R e g is t e r . By order of the Board of Governors, December 11, 1972. [ seal] M ic h a e l A . G r e e n s p a n , A ssista n t S e c r e ta r y o f th e B oard. [FR Doc.73-76 Filed 1 -2 -7 3 :8 :4 5 am]