Overview

The manner in which Safe Deposit Box (SDB) keys are stored is of utmost importance. If a client makes a claim regarding lost or stolen SDB contents, one of the first areas about which the client’s attorney may question the bank is the care of its keys. 

It is critical that the bank not be found negligent in the area of key control. 

• Associates must complete SDB training prior to handling SDB keys.
• Each individual SDB must have an effective/working lock. Key control must be continuous from the moment of lock installation.
• It is important to stress to clients that the bank’s guard key is not a skeleton or master key. The guard key will not open individual boxes.
• Only the client’s key will open the box to which it is assigned. It should be clearly conveyed to clients that the bank does not have access to a rented SDB.

Unrented and Out-of-Service Keys

All keys for unrented boxes and out-of-service box keys are stored in a CCB dual control safe box or other approved locked location that is ONLY opened under dual control. The unrented and out-of-service box keys must be stored separately, within the Capital City Bank (CCB) dual control safe box, to distinguish between the two types of keys within the locked location.

In order to prevent liability to the bank, and personal liability for the associate, it is critical that these procedures are followed:

• Two authorized associates are required to complete the entire process of obtaining keys, testing keys to ensure they work properly, and examining the box to make sure it is empty and in good condition prior to giving keys to a new renter.
• A SDB that has a key missing will not be rented.
• A SDB shall have no more than two keys.

Guard Key

Always refer to the Guard Key as the guard key. Do not refer to the guard key as the master key, passkey, or bank’s key. 

• Keep the number of guard keys to a minimum.
• No one (including unauthorized associates, Officers, directors) except for authorized trained associates should be permitted to use the guard key.
• The guard key must be kept in the physical possession of the authorized associate or kept under lock and key at all times when not in use. Keys kept inside the vault behind a locked day-gate meet this requirement

Client Keys

SDB keys that belong to clients must not be held, retained or stored by CCB or any CCB associate. Do not accept the client’s keys for safekeeping as this may make you liable for any missing items. Do not leave the client’s key in the box door after removing the box. Note: Client keys should always be in the client's possession or in their view under dual control.

Day-Gate Key

The vault day-gate MUST remain closed and locked once the main vault door is opened.

A community key is permissible and must be secured in a selected location where no one other than an authorized associate has access. 

It is permissible to issue day-gate keys to authorized associates requiring regular access to the vault (for example: Teller Experience Supervisor, Personal Banker and Client Experience Manager).

Returned Keys

SDB key control is critical. If not in a client's possession, keys must be stored in one of the following locations:

• CCB Dual Control Safe Box
• Safe Deposit Key Drop Box
  

• Key(s) received from client when closing a box
• Key(s) mailed into the office
• Key(s) found by individual

Associates must accept key(s) turned in by individuals. Associates are responsible for securing returned key(s) in the Safe Deposit Key Drop Box for safekeeping.

• ALL procedures for testing returned keys and closing the SDB MUST be completed before returning the keys to the CCB dual control safe box. See Closing Safe Deposit Box In-Person and Closing Safe Deposit Box –Client Not Present for more information.

The associate accepting the key(s) must deliver them immediately to the CCB dual control safe box. If, due to staffing issues, you are unable to return the keys to the CCB dual control safe box with 2 authorized associates, the keys must be immediately placed in the safe deposit key dropbox.

If more than two keys are returned or found, destroy the excess keys immediately under dual control.

• In the SDB Closing # Keys Returned column, enter the number of keys returned
• In the Comment section, enter a note that the box is closed and record the closed box number

Destroying Keys

If more than two keys are returned or found, destroy the excess keys immediately under dual control.

Destroy keys by pounding them with a hammer or breaking them in half with pliers. The objective is to batter them so completely that they cannot be used or duplicated.