The COVID-19 pandemic has presented many challenges to everyday banking operations, including how to safely permit customers access the content within safe deposit boxes. This article presents some considerations for banks reviewing their safe deposit policies and procedures in light of the ongoing pandemic.
Because there are no Wisconsin laws specific to safe deposit box leases, rules regarding access are primarily governed by contract, policy, and procedure. Thus, their operation is unique to each institution. As such, each bank should consider its own situation when determining how to handle its safe deposit box operation. Each bank’s overall reopening plan will also play a role in how safe deposit box access is handled.
As Wisconsin starts to reopen, many banks have likely already begun to consider safety precautions and when and how to implement. Many of these considerations that apply to overall operation (for example, lobby access) are also appropriate for safe deposit box operation as well. As such, banks should consider the following:
- Limit how many lessees bank permits in its vault for safe deposit access. Many banks have procedures requiring one or more officers to be present, and limiting the number of persons present will help maintain social distancing. Some banks may consider limiting hours of access as well.
- Provide masks for vault attendants and any officers required in the vault or viewing area. Consider what distancing options are available (for example, is remote viewing an option?).
- Encourage lessees to wear a mask. Bank may even consider making masks available for lessees who arrive without one.
- Promote infection prevention measures by providing handwashing instructions, hand sanitizer, encouraging social distancing, and limiting person-to-person contact (ex: handshaking).
- Establish a cleaning and disinfecting policy for the vault and viewing areas.
- Communicate with your customers. Inform them of any limitations on access, and encourage them to plan their access strategically in order to limit frequent access.
While drive-throughs and mobile banking provide solutions for banks limiting lobby access, such options are not available for safe deposit box access. Still, customers may need to access their box during the pandemic, and banks seeking to accommodate them should do so in a way that is safe for all customers and employees.
Want to learn more about safe deposit compliance? Click here to register for WBA's upcoming Safe Deposit Liability Webinar on July 1 to hear more from Scott on various aspects of liability that banks face when managing the safe deposit area.