The Banking Act and Security

Security Management: The 1968 Bank Protection Act In the 1960s, all banking was primarily done in person and in-house—i.e., a customer had to literally walk into a bank to make a transaction. This was well before the era of digital cash, when money could be moved from one place to another with the click of a few buttons on a keyboard.

In the 60s, cash had to be on hand at the bank in sufficient quantities to meet demand—and that meant banks were a big target for robbers. The 1968 Bank Protection Act was created to protect banks from robberies by establishing minimum security regulations for all banks.

The Act came in response to a string of bank robberies that had occurred in the United States in the years prior—robberies that were easily being committed because banks at the time lacked basic security infrastructure, such as monitoring cameras, automatic locks and other security features.

As the Bank Protection Act states, it was designed “to discourage robberies, burglaries, and larcenies and to assist in the identification and apprehension of persons who commit such acts.” By obliging banks to install security system cameras, the belief was that thieves would be less likely to commit robbery if they knew their image would be recorded on camera.

An overview of the Act shows that it appointed four Federal supervisory agencies, consisting of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Director of the Office of Thrift Supervision—to develop, implement and oversee the set of minimum security standards that the banks and savings and loans they regulated would have to have in order to be allowed to conduct business. Each agency essentially developed and appointed the same set of standards.

The Act also obliges the agencies to direct the management of the banks so that they are more secure and in compliance with appropriate security recommendations and guidelines. The Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Director of the Office of Thrift Supervision all take part in reviewing this process to ensure that it is being done and that security updates have been put into place.

Because of changes in the nature of security systems today, this process is a little different in terms of what compliance is needed—however, the same method applies. The banks themselves are overseen by their respective boards of directors, which in turn report to the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, or the Director of the Office of Thrift Supervision.

Each bank’s board of directors is held accountable by the agencies and every bank is tasked with developing a security plan and appointing a security officer to the staff. The banks are also supposed to develop standardized protocol with regards to opening and closing their banks. Officers and employees are to be trained in security measures and annual reports are to be made to the banks’ boards with respect to the effectiveness of the banks’ security operations.

These reports are written by lower level managers who are responsible for managing the systems at the lower end of the hierarchy and reporting the results to upper management. Thus, the system of management to oversee security, as stipulated by the Act, starts with one of the four agencies in one of their respective sectors, then goes to the board of directors of the individual banks, and then to managers of the particular regions and then to the managers of the local branches.

From the head of the four overseeing agencies to the head of the local branch, the chain of command is essentially passed with respect to the 1968 Bank Protection Act. If the local branches are not in compliance, the board of directors will have to answer to one of the four agencies tasked with overseeing the particular financial sector in which that bank is situated.

The local and regional managers will likely be held accountable to the board if the board has already issued directives on updating security and they simply have.