Demonstrators are expected to swarm Bank of America Corp’s annual shareholder meeting on Wednesday to voice anger over a range of issues from foreclosures to corporate taxes to financing for the coal industry.

Anasyst Comment: Spring shareholder meetings have been a prime target for the Occupy movement, particularly those at big banks. For the Bank of America shareholder meeting, we expect to see unions, Occupy and environmental groups team up for mass demonstrations against the bank as 1000 people are expected to converge on the meeting. In April, approximately 500 protestors amassed at the Wells Fargo shareholder meeting, which resulted in 24 arrests. There is a strong possibility that we will see similar activity today in Charlotte.

Around 50 activists have occupied parts of the London Stock Exchange and Paternoster square as part of May Day protests in London. Members of the Occupy movement and Anonymous – better known for its online hacking activities – have also erected a number of tents inside the square which is privately owned and the subject of a previous court injunction banning occupation protests.

Analyst Comment: May Day represents “International Workers’ Day” so it is no surprise that protesters worldwide took part in it today. Anti-capitalist groups in London have organized the rallies and demonstrations in the past. In London today, the demonstrators who took part in the action to occupy Paternoster Square felt they achieved a victory against the injunctions currently in place.

AND ON-AND-ON THEY GO !

 So, does your financial instruction have a structured ” Civil Disturbance” policy ? The following policy sample is generic in nature and only serves to prompt your thinking  in simulating your own  company policy.

This document establishes certain guidelines to follow in the event of a civil disturbance. These  guidelines are developed to ensure the safety of the institution’s  employees and customers and the protection of assets. This plan of action is divided into two main sections: (1) Demonstrations limited to a public thoroughfare such as a sidewalk or street. The local law enforcement agencies should take control of this type activity. However the institutions Security Department should be ready to sign a complaint if necessary. (2) Demonstrations expanding to the company’s private property such as a banking lobby, a board room  or parking deck. A sensitive  but firm approach should be taken to this activity.

 Since these type demonstrations are unpredictable and can develop rather rapidly with little prior warning, two general scenarios should be addressed here:

PUBLIC CONTACT LOCATIONS DISPLAYING ORDERLY CONDUCT (BRANCHES, PUBLIC ACCESS AREAS

As long as the demonstration is orderly and business can be conducted safely and orderly, consideration should be given to allow the branch to remain open with the following stipulations.

• Senior Management spokes persons should be limited to one. This person should be prepared to make a decision to close the branch if, in this person’s opinion, the demonstration is getting disorderly.
• A member of Security should be stationed inconspicuously at the location in plain clothes. This person should report their observations to the Senior Manger present in order to assist the manager in making decisions.
• The law enforcement authority should be advised of any decision to remain open. This notice should be given by Security.
• The manager should insure the teller cash is kept to an operating minimum by having tellers continually sell cash to the vault.
• The office manager should continually be observant to a possible conflict and avoid any type confrontation.

 PUBLIC CONTACT LOCATIONS DISPLAYING DISORDERLY CONDUCT (BRANCHES PUBLIC ACCESS AREAS.

If the demonstration becomes disorderly and it becomes difficult or unsafe for employees or customers, the following action should be taken in the order given.

• The Senior Manager present should advise the Security Manager to close the branch.
• Security should notify the local law enforcement agency, the highest ranking Senior Manager, and the Marketing Representative of the branch closing.
• The vault door should be closed and locked with no time on the clocks.
• Security, in conjunction with law enforcement officers, should escort the working personal and customers to a safe location within the building or to their cars depending on the type building and time element.
• The senior employee present should make the announcement to the demonstrators that the building will be closed in five minutes or at a certain time such as __________ o’clock, and that everyone is requested to leave.
• If the demonstrators do not leave by the designated closing time, the senior employee should identity the group leader and instruct the leader that if the group fails to leave within another approximate time period, the law enforcement agency would be requested to arrest the group for trespassing.
• If the group chooses to remain, they should be arrested and a complaint signed by the Security Department.
• If the demonstrators leave the interior of the building, but choose to remain on the property, the same procedure listed above should be followed, as appropriate.

 NOTE:

In multi-tenant buildings in which the banking office  is a tenant, the building owner should be required to make any decision outside of the bank’s leased space.

If the building is a non-public contact processing center environment, such as a bank operation center, demonstrators should not be allowed to remain on the property. The same exit warning procedure listed for the branches should be followed. Employees should be instructed to remain inside the building until all demonstrators have left.

ADDITIONAL PRECAUTIONS TO TAKE IN CIVIL DISTURBANCES AND PUBLIC PROTEST

• Lock exterior doors and station employees at them to admit selected people.
• Close all drapes to lessen danger of flying glass.
• Shut off unnecessary motors, such as air and heating.
• Turn off utilities.
• Shut off elevators  and/or lock stairwells.
• Draw emergency water supply into available containers.
• Remove from plain view any object which could be hazardous or which could be used as a missile.

NOTE:

Never make any statement to news media.

  Always Remember!

Since these type demonstrations are unpredictable and can develop rather rapidly with little prior warning, always be prepared. Regular refresher training is of the utmost import ants.

This author always stands ready to assist in any type security/safety policy drafting or  training material. such as  “Power Point presentations”.

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(Can you imagine the time, effort and cost involved in reconstructing the banks proof work (cancelled checks, special delivers branch supplies, etc) if an attacker suddenly way-laded the banks carrier, while traveling from the bank branch to its operation center?  Believe me, I’ve been there and done that and it’s no cake-walk.

All an attacker would need do is to spend some time in observation of the courier’s routes and time schedules, within most banking organizations.  As in all banking security procedures, however, this exposure can also be reduced by certain precautions.)

Non-negotiable banking documents can potentially be devastating to both the bank and the customer, if the items happen to get destroyed. And, re-constructing such items, such as checks, can and will be quite costly, if such courier deliveries do not arrival as planned.

So, what is a bank courier and what do they transport?  Simply put, a bank courier is defined as any bank employee transporting in their possession non-negotiable bank property from one point to another. Usually from the banking branches to the banks processing center. So, let us review the bank courier security in a little more detail.

COURIER DELIVERIES

Proof work, special deliveries and branch supplies should be transported in secure fire resistance containers.

CONTRACT SERVICE

Where practical, the above mentioned items should be transferred by banking in-house personnel. When such service is not available or is not cost effective, such as interstate air transports, a contract service can be utilized. In this event, the banking legal authority should draft a very specific contract, in protection of the bank, specifying that the contract service be responsible for any recovery cost, if document reconstruction is necessary.

COURIER EMPLOYEE SECURITY

• When possible, couriers should park at a location where the vehicle can be observed from within.
• Courier vehicle doors should be locked at all times whether parked, moving, vacant or occupied.
• Couriers should always be on the lookout for suspicious situations. Especially, when the same vehicle is observed over and over.
• If the courier feels followed, the courier should continue past the next scheduled stop to a safe location and notify the police.
• The courier should not stop, for any reason, while in route to or from a location, except for an emergency.

VEHICLE SECURITY

• All vehicles should be unmarked.
• All vehicles, when possible, should have lockable trunks, electric door locks, audible alarm buttons on the remote key ring and fire extinguishers.
• Vans and camper shell pick-ups should have lockable rear compartments separated from the vehicle cabs.
• Private vehicles should not be used by bank employees unless approved by the bank Security Officer.

COURIER SCHEDULING  

• Each banking location should have an updated copy of the courier schedule.
• If a courier does not arrive within a fifteen minute period after expected, the courier supervisor should be notified. The banks security manager and the police should be notified, if the delay cannot be explained.

TRANSPORTATION

• All proof work, special deliveries and branch supplies should be transported in the vehicles locked trunk or a locked rear compartment.
• Transportation should be confined to the bank personal only, with no consideration given to so-called friends or hitch hikers.
• Couriers should not travel armed. If necessary, under special circumstances, this duty should be by an armed guard or member of the banks security department.

CONTAINER CONSTRUCTION

• Local delivery containers should be constructed of a low impact type material such as plastic or cardboard.
• Over-the-road containers should be constructed of a high impact fire proof type material such as heavy cloth or metal,

VEHICLE COMMUNICATION

• If the bank has a twenty-four hour alarm monitoring console, the vehicle could be equipped with two way radio devices.
• If no radio communication is available, the couriers should be equipped with cellular telephones.

Remember, even the most effective communication system is of little use if, during an emergency response, staff members cannot tell others their location. This problem can be reduced with the purchase of global positioning system (GPS) terminals. Inexpensive, small and lightweight, these terminals have become standard equipment for hikers, truck drivers, and aircraft. So, why not include the GPS technology in courier transportation.

TRAINING

• New couriers should be trained on all phases of the operation within a month of employment.
• Additional training sessions should be held at intervals no longer than six months.
• Training sessions should concentrate on the latest criminal trends against the banking courier industry.
• Banking courier security policies should always be reviewed.

LESSONS LEARNED

Within two weeks after an attack or loss, the bank security department should analyze the occurrence and prepare a critique to include:

• Procedures that proved faulty and must be changed.
• Loss or injury resulting from failure to follow procedures.
• Successful application of procedures that resulted in the elimination of reduction of loss, prevention of injury, or apprehension of an attacker. 

PUBLIC RELATIONS

The fact that a loss or attack has occurred and the details of the occurrence should be communicated only to those who have a “need to know”, this is necessary for the protection of the loss items and to avoid customer panic. 

CONCLUSION

Remember, there are many structural and procedural steps, most of which do not reduce efficiency or effectiveness, which will tend to deter criminal activity against the banks couriers. Ideally, these steps will be so subtle that they will not be offensive to the parties involved but so apparent that criminals will go elsewhere. Not all losses or attacks can be prevented, however, as there is no absolute defense against a determined attacker and some attacks are made by persons not rational enough to perceive the deterrents.  For these reasons all necessary steps should be taken continuously, to minimize such losses when attacks occur.

(For assistance with this subject or any other security subject, please contact this Author)

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Someone once said, “the road to success is paved with reports”. That old cliché certainly rings true, in today’s corporate world. I once visited a “fast food” restaurant office, only to be amazed at the number of grafts and charts pinned to the wall. Why, you would think it was anything but a hamburger joint.

The same theory holds true in the security world. Especially in the banking industry, as the banks have so many rules and regulations to tend to, spanning from the various federal regulations to the local state and city security rulings. Not to mention the bank Security Policy Manual.

So, is your “Investigative Unit” having trouble proving its worth to your bank management? For some unknown reason, bank security always seems end up being on the low end of the preverbal bank budget “totem pole”. Well, speaking from experience, this idiom is easily fixed. Your department already is probably proving its worth, in fraud prevention and assets recovered. It’s probably just not proving the accomplishments on paper. After all, most banking executives want that piece of paper in front of them, when looking to develop the budget. Yes, the road to success is truly paved with reports. Let’s see if we may change this posture for your department.

FRAUD CASE REPORTS
Investigators should be responsible for making the following reports a part of each fraud case file.
Investigative Report- Should is completed on closed or cleared cases. Multiple incidents of fraud, concerning a single victim, should be considered one case.
Investigative Notes- Should is on-going as contacts are made. Giving a chronological record of the chain of events.
Supplement Report- Should be completed when a case is re-opened or reassigned after the Investigative Report is completed when new information is obtained or as an addition to the original investigative report.
Status Report- Should is updated as cases progress with a copy being sent to the effected manager as needed or when a case is closed or cleared.

Note: The status report remarks section may be completed in lieu of the investigative report on priority cases when no chronological documentation is required.

EXTERNAL- INTERNAL FRAUD REPORTING
Investigators should be familiar with and abide by the banks guidelines on these matters. Internal fraud should only be investigated and reported upon request of the banks Audit Department. While, external fraud should be investigated and reported based on the merits of each individual case leads and not necessarily the amount of the loss.

MONTHLY REPORTING.
Investigators should be responsible for compiling a monthly report each month giving all statistical information on cases worked, court dispositions and restitution obtained.
This report is vital and should be consolidated and distributed to senior management monthly. This is where the “rubber meets the road”. This consolidated report should always show the amount of bank funds recovered, as well as the precautions taken in all loss preventive measures.

CASE PROGRESS REPORTS
It is also vital to establish an effective case progress reporting procedure between security and other various internal and external contacts having a mutual interest in the investigation. Especially, when bank funds are recovered.
Investigators should be responsible for communicating oral or written progress reports. On a need to know basis, when a significant event occurs in the investigation, i.e. arrest, warrant, restitution, or case closed, etc.
Oral progress reports should be communicated by telephone or in person when practical.
Written reports should be communicated by reproducing investigative notes or status report. No emails or other social median please.
Note:
Information of a confidential nature should be reviewed with the security manager before being communicated externally or internally.

FRAUD INVESTIGATION CASE PRIORITY
External fraud investigation (checks, cards, etc.) should be conducted in accordance with the following priorities.
Priority One- Suspect is known and/or loss exceeds $1,000.00.
Priority Two- Witness and suspect many be developed and/or loss exceeds $200.00.
Priority Three- Witness and suspect cannot easily be developed and/or loss is less than $200.00
Note: This is strictly a recommendation. Consideration must always be given to your bank policy.

The following investigative guidelines are given to assist in the evaluation and qualification of assigned cases, in connection with your bank policy.
• Is there an actual or potential personnel safety problem?
• Is there a question of employee integrity or ethics?
• Is the asset loss amount or potential loss amount cost effective? (Worth it)?
• Does it involve unusual or sensitive issues as defined by management?
• Is the incident method used unique or one of a series or patterns developing?
• Is the subject known or not?
• Is it a unique contact or a repeat problem individual or group- employee-customer-other?
• Is the geographical location cost effectives?
• Is there available evidence- witnesses-accurate suspect identification- license numbers, documents, pictures, etc?
• What is the length of time since incident occurred?
• If necessary, is the incident referable to the criminal justice system?
• Is it a violation of the law?
• Will the law enforcement authorities, and/or the prosecutor’s office accept the incident for processing?
• Is the incident family related?
• Was the incident “preventable”, on the part of the bank, if in the opinion of the prosecutor adequate due diligence had been exercised during the new accounts or application process. Specifically this relates to credit card and new checking accounts?
• Overall, based upon the variables, how does an individual incident when compared to dozens of others rate in probabilities of attaining the investigative objectives of prevention, recovery or loss prevention and successful referral to a criminal justice agency?
• How available is an investigator and how can a new case best fit in or coordinate with the investigator’s current work load?

Please Remember! When a member of management, especially a senior manager, requested case is turned down, always give a ligament reason, such as listed above, for not accepting the case. Just be fair and truthful, and management will usually understand.

FIELD OFFICE DOCUMENTATION-(Where Applicable)
Each resident investigator field office should maintain the following mandatory documentation.
Library- Each library should consist of a bank security plan and alarm manual, an Investigator General Orders Manual, an emergency operations disaster plan and an emergency telephone contact list.
Investigator Case Docket- Containing an up-to-date court assignment. List.
Filing System- Containing a general file, a case pending file, a case suspense file and staff memorandums.
Staff Conferences- Consisting of staff conference minutes.
Staff Training- Consisting of staff training articles.

So, now you have It., the bottom line. Just prove your worth and management will be proud. In a former life, our security department consistently recovered funds or documented preventive losses in excess of the entire security budget, month after month. And, as a result, our department quickly grew from one local Investigator to four Regional Investigators.

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And if your bank is hit by a robbery at closing time, several things are likely. The robbery has been carefully planned, there’s a chance someone on the staff has been involved and the results can be devastating.

So, does your bank have a “closing procedure” or a “closing check list”? If not, why not. After all, as a banking official, you have been given certain mandates by the Board of Directors, as mandated by the Bank Protection Act (BPA). And, the number one priority is the protection of your customers, your employees and the bank’s assets.

CLOSING PROCEDURE OBJECTIVE

The closing procedure is much like an Opening Procedure, only in reverse order, with the objective being:

• The protection of employees involved in the closing procedure.
• The protection of customers who might still be present at closing.
• The protection of assets from loss during the bank closing.
• The protection of assets, from an indirect loss upon closing, in which someone is injured or killed and the bank is held partially responsible.

CLOSING PROCEDURE

• At the end of the banking hours an employee should lock all doors giving access to the banking lobby, and activate the lock or other device, (dead bolt locks, door bars) which makes it impossible to unlock the doors from outside. This should be done only after the lobby is surveyed for suspicious persons, such as checking the coupon booths, where someone could be hidden.
• As quickly as customers are served they should be escorted to the door and permitted to leave. After doing so, the doors should be relocked, as mentioned above.
• When all customers are believed to have left conducted an additional thorough search, of all areas where someone could be hiding, such as the restrooms and the break area.
• During the process just described, no one should be admitted unless positively identified and at least one employee who has unobstructed view of doors, lobby and teller stations should be positioned at an alarm activating device.
• The vault, or chest or safe with time locks should be locked as soon after the end of banking hours as possible.

Please note: Activating an alarm after normal business hours may generate a serious occurrence. If not properly trained.

However, the following procedures should take place before the above actions are carried out:

• All tellers have balanced or steps taken when out of balance have been performed.
• All compartments in which currency is stored have been inspected. These compartments should be unlocked and left open, so as to show no cash is stored, during non-banking hours.
• All currency station trash cans have been inspected.
• All compartments outside of the vault in which coins are kept have been inspected to ensure they are locked.
• All areas in which securities and valuables other than cash are kept have been checked and such items have been locked in the vault.
• The night depository has been locked using both the key and combination and the keys placed in the vault.
• Time looks, on proper storage areas, have been set and checked.

Then, after all closing procedures have been properly carried out the last person leaving the banking lobby should

• Open all blinds and curtains, including those at the drive-in window.
• Turn on all night lights not controlled by a timer.
• Lock all exterior doors.

Additional Security Tips:

• Robbers don’t just run in without doing some surveillance.
• All closing functions should be carried out under employee “duel control” ( always two banking employees)
• Vault time locks should be set to allow opening no earlier than 30 minutes before bank opening.

In the interest of time, each banking employee should be assigned certain closing duties and a written check list kept of each employee’s responsibility. These responsibilities should be rotated regularly.  

As critical as the closing procedure is, these procedures should regularly be discussed in each bank staff meeting. In other words, a “proactive”, rather than a “reactive” approach should be taken. Being prepared for a bad situation is the best way to keep everyone safe.

Please remember, bank’s go to great lengths to protect its employees and customers during the closing procedures. And each employee should understand, though the procedures may be time consuming, the procedures are designed for their protection…

Please Note:

Certain procedures, mentioned in this article, are general in scope for security rationale. For a detailed explanation of these, or any other banking security policies, please contact this author.

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Simply put, workers compensation is basically an insurance policy to protect the worker, in case of an on-the-job accident. Thus, an injury to an employee is considered compensable only when the following facts exist:

1. There is an accident.

2. The accident occurred within the employee’s capacity of employment.

3. The injury is fundamentally related to the accident.

4. The employer has been notified.

Workers comp laws are basically designed to provide a satisfactory means of handling work place injuries and disabilities. In other words, workers comp laws state that the employer must assume costs for all work place injuries. Basically:

1. They provide sure, prompt, and reasonable income and medical benefits to work place accident victims, or income benefits to their dependents, regardless of fault.

2. They provide single remedy and reduce court delays, cost, and workloads arising out of personal injury litigation.

3. They eliminate large payment of fees to layers and witnesses as well as time consuming trials and appeals.

4. They encourage maximum employee interest in safety and rehabilitating through an appropriate experience rating mechanism.

5. They promote a study of the cause of accidents, rather than the concealment of fault, reducing future accidents and human suffering.

THE IMPORTANCE

Investigating worker claim injuries is a necessary tool for preventing recurring claims. And, if anything positive results, it is the opportunity to determine the cause and how to elimate future occurrences. When problems are resolved, a safer and healthier work environment will result.

THE PURPOSE

Simply put, the purpose of any workers comp claim investigation is to determine the cause and recommend corrective action, which will eliminate or minimize the claim. The investigation should take on a proactive rather than a reactive posture, as the entire procedure should always be aimed at fact finding, rather than fault finding. This does not necessarily mean that oversights or procedures, that were carried out incorrectly, should be ignored. Nor, does it say that personal responsibility should not be determined, at the appropriate time. It means that the investigation should be concerned with only the facts. In order to do a quality investigation, the investigator should always be objective.

EMPLOYEE NOTIFICATION

It is essential that all accidents be reported to the supervisor immediately, regardless whether they result in personal injuries, illnesses or property damage.

PLEASE REMEMBER, IN ORDER TO HAVE A SUCCESSFUL WORKER’S COMP POLICY, THE POLICY SHOULD ALWAYS BE A PART OF THE NEW-EMPLOYEE INDOCTRINATION PROGRAM.

MANAGEMENT REPORTING

All accident claims and losses should be reported in writing to the appropriate insurance carrier, within 24 hours after the occurrence. Claims involving serious injury or death should be reported immediately.  Prompt reporting enables the insurance company to take immediate action, which may contribute greatly to the control and reduction of cost of claims. It also helps the company meet the legal requirements, required by law.

CLAIM MONITORING

Once an employee has been injured, the corporate management should continue to tract that employee, until the employee returns to work or the employee is released from the job. While away from the job, the employee is totally non-productive, yet is being paid. So, it is imperative that the employee return to work quickly in order to keep the budget in tow.

So, how is this accomplished? The key is good communication.

1. Communicate habitually with the injured employees. In other words, just don’t forget them. Employees who do not hear from management will feel that management is not concerned and that there is no hurry to return to work. The longer the employees are out, the harder it is to get them back to their regular duties.

2. Consider visiting the employees at home, to show concern for their injuries.  

3. Communicate with the insurance adjuster, by regularly keeping in touch with them. This should serve to demand good service, by discreetly being involved. And, also assist in keeping the adjuster abreast of the case progress.

Please remember, do not assume that an illness or medical complaint, reported by an employee, is automatically work-related and covered by workers comp insurance. All such employee claims must be thoroughly investigated and recorded.

LIGHT DUTY WORK

An employee must be able to perform their regular and customary duty in order to return to work from a work place injury. Employees who receive a full medical release, from the company doctor or the worker’s comp appointed doctor, may return to work as indicated by the doctor. However, on occasion an employee may be released with certain medical restrictions that prevent the employee from performing regular duty.

If there are positions available within the company that need to be filled and the injured employee is medically qualified to perform such jobs, the company management is encouraged to offer the disabled employee a temporary change in job function. This should only apply if:

1. There is a position available to be filled.

2. The employee is medically qualified to fill such position.

3. There is a specific time period determined, for instance 30 days or 60 days and then the employee will return to regular duty.

The Human Resources and the Legal Departments should be notified in writing when the employee is being reassigned to an alternate job classification due to a work related injury.

If the company is a “union shop”, the union representative should also be notified as a matter of courtesy.

SAFETY CONCERNS

One of the most important considerations of any safety program is to conduct “proactive” rather than “reactive” accident investigations. All accidents, even minor ones, should always be investigated because today’s minor injury could result in tomorrow’s serious injury, if the causes are not found and removed.

A PERSONAL APPLICATION

A little over seven years ago I was traveling in a remote part of the country, on my way to visit a client, when my life was forever radically changed. In a blink of an eye, I was the victim of a near fatal vehicle accident.

I really don’t remember what or how it happened, other than seeing the wreck report details, as I lost complete consciousness for a period of time. According to the official record another driver attempted to cross the four-lane highway, on which I was traveling, and T-boned my vehicle. Both the driver and passengers, of the other vehicle, walked away from the accident. However, the driver was charged with multiple traffic violations, of which he was convicted in the local city court.

Later, as I gained my composure at the scene, I remembered seeing and hearing the medical personnel cut the twisted metal of my vehicle in an attempt to free l me from the wreckage.  

After a two month hospital stay needed to mend my crushed body, followed by several weeks of extensive physical and occupational therapy, I initially returned to temporary light work duty. Then, about 10 months after the accident, I was cleared to return to my regular job, under certain workers comp doctor’s restrictions. I continued this limited work duty until my retirement, about 2 years ago.

In order to evaluate my work restrictions, with respect to my returning to work, I underwent a comprehensive computerized “Functional Capacity Evaluation (FCE). This evacuation determined that I had reached my “Maximum Medical Improvement” (MMI) and that I had also reached my “Partial Permanent Impairment” (PPI) rating. This PPI rating was calculated by combining the value the PPI percentage of the whole person for the left upper extremity with value of the PPI percentage of the whole person for the left lower extremity to reach a total PPI percentage value of the whole person.

My workers comp settlement was then based on the conclusion of these evaluation factors, in accordance with the state workers comp law. Conversely, the workers comp insurance carrier also has an additional mandated to take care of my claim related lifetime medical needs.    

Please Note:

This article is general in scope. Each state law is different, with respect to the workers comp laws. So, please do your proper research, in familiarizing yourself with the needed information. 

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The primary objective of any rental company is to make a profit, protect the company’s assets and remain competitive in business. While, the primary customer objective is operating the equipment safely. Thus, in both cases, safety plays an important part in attaining these objectives. Safety should be an essential element in the daily rental field operation and a vital part of every rental manager. Effective managers have learned that good safety pays off in dollars and cents. Moreover, indirect rental safety precautions lend themselves to increasing productivity thus increased profits.

In the rental business the corporate philosophy regarding safety should clearly be an important part of the daily activity. And this positive attitude should be passed down to the rental customers. So, keeping safety in mind, why rent? • In many jurisdictions, rentals used for business are considered to be tax deductable.

 • Sometimes a financial inadequacy is involved, such as one is not able to buy the needed equipment.

• The need to reduce financial risk. • The need of preventing the heavy cost of equipment deprecation.

 • The need of long term budget planning.

The replacement of equipment owned verses the rental of equipment, as needed. Then there’s the transfer of liability issue. In other words, if you rented a certain tool and were accidently injured or killed, as a result of using the rented tool, which would be charged with the equipment negligence, assuming that equipment negligence was a factor in the accident? Well, one need only to pick up the local newspaper or tune in to the nightly TV broadcast, to see that if this scenario happens, anyone having a slight bit of perceived responsibility, from the rental company, to the equipment manufacture, to the equipment operator, would receive that infamous subpoena. So, go ahead, and do that those much need improvements in your company, in your home, in your garden, etc. Just do a little safety research, in choosing the right vendor. Here are some tips to ponder. These tips are not “all inclusive” but just may prompt you to put on your thinking cap, as it pertains to your business and safety needs.

 • Check out the rental agencies track record, with the local (BBB) Better Business Bureau.

• Check out the rental agencies safety tract record.

• Does the rental agency offer 24 hour emergency service?

 • Does the rental agency have a precise “rental protection plan”, that covers such needs as equipment theft and damage protection?

• Does the rental agency have any hidden fees, such as environment fees, equipment abuse fees, etc?

 • Does the rental agency require a “credit check” on large ticket rentals? • Does the rental agency have the proper tools to get the job done?

• Consider your inventory and storage needs. Does the rental agency have cost breaks for long term usage?

• Consider the rental agencies delivery policy, regarding the transportation of the equipment. How and who is responsible in getting you the needed equipment? And, who assumes the cost of such?

• Check out independent references, such as your safety contractor friends, as to which rental agency they routinely use.

 • Check the agencies policy, regarding equipment malfunction and equipment break down.

 • Check the agencies insurance liability coverage, as it addresses a third party liability.

• And finally, check out the IRS web site, business section that addresses the “Passive Activity Loss ATC”,

Chapter 2, Rental Losses. Remember, one can just as easily get hurt, while using rental equipment, as using owned equipment. Here are some safety tips, when using specialized rental equipment.

• Make sure the rental equipment is in good working order.

• Mark sure the equipment functions are operable.

• Observe all warning labels.

• Make sure equipment is maintained according to the manufactures specs.

• Be properly checked out on all equipment usage.

 There are many other ways to promote safety when renting equipment and it’s the dealership’s job to make sure the equipment is in good working order and the customers are aware of the risk involved, as well as decreasing the risk of danger. So dealers, plan to assist your customers by taking the time to implement a risk management strategy and keep your business running smoothly by:

• Documenting all equipment service, repairs and preventive maintenance.

• If vehicles are involved, make sure the vehicles meet the (DOT) Department Of Transportation standards.

• Always adhere to the (OSHA) Occupational Safety and Health Administration requirements.

• Always give written instructions on how to operate the rental equipment. Remember, each and every rental employee should have a safe and healthful working environment.

To be certain that this high standard is maintained, it is the responsibility of every rental manager, to treat safety with the same respect and level of importance that is assigned to productivity and customer relations. A final tip for both the rental agent and the customer, ” always assume a “safety first” attitude. A proactive, rather than a “reactive” stance, will go a long way in protecting all concerned. Authors Note: Once when considering several security vendors, for a bank I representative, I learned a good practical lesson. Just get hold of five year old telephone yellow pages and see which vendors are still in business. It is said that most failed businesses, fail within the first five years of being in business. The same probably holds true with any rental agency.

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Every year many innocent bystanders are doped out of large sums of cash, by professional “flim-flam” artistes, by way of well organized deception and fraud schemes.  And, for some reason, these con artistes seem to pick on the misfortunate and elderly.

 A simple definition of “Flim-flam states, “when you cheat people out of their money or a trick to get peoples’ money”.

Often times, a bank teller may innocently get caught up in a well organized plan to swindle individuals out of their bank funds. When this happens, the bank must have a definitive plan to help prevent such a move. Following, is a sample “Swindle Warning” policy, designed to help prevent such a loss.

SWINDLE WARNINGS

• Each teller, and banking lobby official, should have a supply of the “Swindle Warning” forms, to review with the customer.
• When the teller is suspicious of a cash withdrawal, the “Swindle Warning” should be given to the customer and the teller should vocally emphasize the importance of the warning.
• If a customer persists in the withdrawal and the teller still believes the customer is being victimized the teller should politely request that the customer sign the warning. Signing the warning should not a requirement for the withdrawal. However,   if the customer voices opposition, the teller should insist on a signature. If no signature is obtained, the teller should make a notation on the form that the customer was warned and refused to sign the document.
• If the customer persists in the withdrawal, after the teller has requested a signature, the teller should alert the banking manager.
• If suspicion persists that a swindle is in process, admitted by the customer or not, the teller should activate the security cameras as long as necessary to get proper pictures of the customer and of all others in the lobby.
• While counseling or questioning a customer, great care should be giving not to endanger the customer, as the swindle artist may also be in the banking lobby. Always, the first duty is to protect the customer. Next to the customer’s safety, comes the desire to catch the swindler.

A SAMPLE SWINDLE WARNING FORM

WARNING-PLEASE READ AND SIGN

Every year thousands of dollars are loss to swindle artist. You are about to make a large cash withdrawal. If you answer “Yes” to any of the following questions, YOU are likely an intended VICTIM.

Please check the questions that apply to your withdrawal.

• ____Have you been asked by a stranger to make this withdrawal?
• ____Were you contacted or visited by someone claiming to be a police officer, federal agent, bank examiner, or auditor?
• ____Were you ask to help in an investigation or to help catch a crooked employee?
• ____Were you told to give the money to a special agent at your home or at another location?
• ____Have one or more strangers offered to share a large amount of money with you if you put up the money in good faith?
• ____Has a stranger come to the bank with you?
• ____Have you been told not to tell anyone why you are withdrawing the money?

If you answer “YES”, to any of these questions, please ask the teller to call the security officer, another bank official or the police.

If after reading the above, you continue to wish the withdrawal, please sign and date this warning.

Signed ____________________________ Date___________________

Tellers seem to always be in the forefront of this type scheme, basically because they are the ones who handle the cash. However, from time to time, other banking officials may also be approached. So, it is very important that all banking locations have an up-to-date precise   “Swindle Warning” policy.

Please note: This article is only a sample, addressing the so-called “Confidence person” or “Bunco artists”. It is not intended, not does it claim in any way, to be the all inclusive solution to the crime. Each banking location is urged to consult with the proper auditing, legal and security authorities, when planning the banks “Swindle Warning” policies.

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And overall, safety should take priority in the hiring process to be assured of the hiring of qualified employees. The “taking precedence” and hiring the best qualified employees will always serve to help prevent company loss at the transportation level.

 Conversely the hiring of unqualified employees will bring about needless problems, such as:

• Higher accident rates.
• Needless legal action against the company
• Higher insurance cost.
• Decreased employee productivity.
• Equipment abuse and damage.
• More on the job injuries and workers comp claims.
• The need for increased supervision time.
• The need for additional employee training.
• Fraudulent illegal termination claims.

 Companies should never hire, as a need of expediency and should never give in to the pressures of fast changing employment needs. This procedure will only foster uncaring employee attitudes, coupled with low morale. This practice will get the company in trouble every time. The company should always think and plan ahead, by continuing to keep a collection of qualified applicants to ensure good employment decisions.

Remember, its must easier to take a proactive hiring stance, rather than a reactive firing stance.

 HIRING RESPONSIBILITY

The highest level of line management should do the foot work of recruiting. Screening and making the initial hiring recommendation, in accordance with company policy.

After this process is completed, the company Human Resources should review the recommendation and approve or disapprove the candidate. Human Resources should insure the candidate meets all the company standards.

 MOTOR VEHICLE RECORDS.

The state MVR’s can be a very valuable free tool, in evaluating transportation employees. The documentation should verify if the applicant has a current. Valid operator’s license and a satisfactory driving record. The violations listed on the MVR will probably vary in scope. However, these violations may be used to reflect the application’s driving habits.

The MVR may also be used to reflect either positive or negative on the application’s employment application remarks.

 OUT OF STATE EMPLOYEES

When hiring employees holding an out-of-state drivers license, check both the out-of-state and the state in which the applicant will be hired MVR records.

 PRE-EMPLOYMENT SCREENING

If the company requires pre-employment screening, such as a polygraph test, transportation related questions should be included in the testing procedure. 

 ADDITIOINAL EMPLOYMENT CONSIDERATIONS

• Does the applicant meet all Federal Motor Carrier Safety qualifications?
• Does the applicant have a current commercial (CDL) driver’s license?
• Does the applicant have military trucking experience?
• Has the applicant completed a recognized defensive safe driving course?

 NEVER HIRE AN EMPLOYEE IF CONVICTED OF:

• Driving while intoxicated or under the influence of alcohol or drugs.
• Refusing a law enforcement blood alcohol test.
• Reckless Driving, Negligent Homicide or Manslaughter.
• Having a suspended license or a license revocation for reasons other than failure to pay a fine.
• A chargeable accident involving a serious injury or fatality.
• A motor vehicle theft.
• Filing a false vehicle related insurance claim.

 Remember, always use common sense and never hire a driver with a bad driving history.

SAFE DRIVING REVIEWS

Management supervision should review all employee driver records yearly and document the results within the employee’s personal file. If an employee has:

• More than three moving violations, the employee should complete a defense driving course.
• Excessive violations and accidents, immediate action should be taken to remove the employee from driving, up to and including termination.

 PHYSICAL JOB REQUIREMENTS

All employment driving candidates should take a physical examination, paid by the company. This physician examination should be performed by a company doctor, familiar with the physical job requirements. The doctor should always be available to work with the company to assist management in making a decision on whether the applicant can physically perform the job properly.

 RANDOM DRUG TESTS

Unannounced employee random drug tests should be conducted and the results should be documented in the employee’s personal files. Any drug related problems should be handled in accordance with the company drug policy

 IN CONCLUSION

Remember, the selection of qualified employees is a critical safety factor. The successful manager should always have an understanding, a sixth sense if you will, of the importance of hiring and keeping well qualified applicants.

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Anytime, a corporation serves the general public, by an ” open door” customer policy,  the thought of employees or contacts “going armed” is subject to much discussion and debate. Especially, in the financial  industry where the bank must  deal every day with a combination of customer traffic and the exposure of large sums of inviting cash money. 

This sample “Fire Arms” policy is intended for internal management use only. The contents, herein, should be  construed as creating an informative educational atmosphere, to aid in the creation of a higher standard of employee and customer safety.

A. AUTHORIZATION

Employees, or outside contract personnel, who may be authorized to carry or posses firearms in the line of duty or in company-owned vehicles should  be approved by a member of Senior Management.

1. Each person who believes his/her job content requires or makes beneficial the carrying of weapons should apply for authorization to do so using an Internal Pistol Permit form.(sample form available from author)

Persons not having security duties to whom a company vehicle is assigned and who wishes to have therein a firearm “for protection” should apply in writing to the designed  member of Senior Management, for permission to do so.

3. No one should carry firearms with the intent of “going armed” or “for protection” on company business until he/she has met the above sections 1) or 2) and has received authorization or permission.

B. RESPONSIBILITY OF OBTAINING FIREARMS PERMITS

1. It should be the exclusive responsibility of each individual to obtain his/her permit to carry a firearm.

2. The permit fee should be paid by the company only for armed company guards and full time security personnel. All others should be required to pay  the permit fee personally.

3. Permit renewals should  be an individual responsibility.

C. TRAINING

Persons should be authorized to carry firearms in execution of duties, only after determination by Senior Management that they are trained in the use of firearms, have received instructions and have agreed with the company fire arms policy on use of firearms or other deadly force.

1.An off duty police officer should be considered trained if he/she meets the requirements of the police department by which he/she is regularly employed.

2.Contract guards should  submit a documented outline of firearms training given to the employees. Upon approval of the program and certification by the contract guard services, the guard shall be considered trained.

3. The qualification of all others, including guards provided by a contractor not having an approved program, should only be approved by the company security officer. Consideration should  be given to:

a. Years of experience as a guard.

b. Police experience.

c. Military experience.

d. Other training.

4. If a person is determined to be unqualified, attempts may be made to obtain training at one of the several police academies or any other qualified training program.

D. FIREARMS IN LINE OF DUTY

Only those individuals, authorized to do so, may carry firearms or other weapons, with the intent of “going armed” while on company facilities, in company owned vehicles, or while on company business.These persons are, but not limited to:

1. Uniform guards; contract employees or off duty police.
2. Corporate Investigators, Corporate Security Officers, or the Corporate Security Manager who has no other duties.
3. Other personnel with Security Duties; These individuals may possess firearms on premises, in vehicles or on business but shall not carry  firearms except while specifically engaged in acts a prudent person would interpret as requiring weapons.

E. METHOD OF CARRING FIREARMS

Persons authorized to carry weapons, while on company premises or while engaged in company business should fall under one of  three categories.

1. Uniform Guards- These personnel should carry such weapons, as approved by the corporation,  openly in a “service type” holster.

2. Full time plain clothes security personnel- These personnel should carry firearms and other weapons concealed on the person as provided and authorized under state law. Weapons and holsters should be of a size and type that do not make the weapon obvious.

3. Other personal with security duties- These personnel should carry only when engaged in those few duties a prudent person would interpret as requiring weapons, but may possess firearms on company business. Such weapons may be kept in a desk, a briefcase or in a vehicle and should be stored in such a way that they are secure against accidental discharge, falling into possession of an unauthorized person, or being offensive to persons(customers or other employees), etc.) with whom the employee has contact in non-security duties. When the employee does “carry” firearms , the firearm should  be carried as prescribed for full-time plain clothes security personnel.

F. USE OF DEADLY FORCE

A firearm should never be drawn unless there is strong probability that it will become necessary to fire a shot or shots. Under no circumstances should a warning shot be used.

The use of deadly force, including firearms, should be  justified only when all of the following conditions are present.

1. Defend against deadly physical force directed against the employee or other employees, customers or others on corporate property.
2. Apprehend an individual known to have committed a deadly felony, in the presence of the employee.
3. When all other reasonable alternatives have been exhausted.
4. It does not threaten other employees, customers or by-standers.

(Please note: The company Legal Department should always be involved with this “Use of Deadly Force “section of the company “Fire Arms” policy.  Employees, and customers should always take the route of least resistances, in an emergency situation. In other words, if there is a viable safe route of escape, always take it.)

G. CASUL POSSESSION OF FIRARMS

Causal possession of sporting firearms should not be prohibited, but they should be unloaded and enclosed in a suitable container while on premises. This exclusion is intended only to facilitate such actives as hunting, target practice or transportation for repair.

H. FIREARMS IN CORPORATE OWNED VEHICLES

An employee should not have a firearm in a corporate-owned vehicle for “self protection” unless the possession is approved by corporate management. However, this section should not be considered to prohibit a personal private decision of any right under the law. General, there is no employment related need for such possession and the corporation, having no control, should not assume, nor be legally responsible for any liability which may arise from the possession or use of such firearm.

I. OWNER SHIP OF WEAPONS

1-Employees authorized to carry firearms in execution of duties may use personally owned firearms meeting the criteria of the companies fire arms policy.

2- Handguns will not be purchased by the company except for an employee having full time security duties

J. WEAPON INSPECTIONS.

An authorized manager should hold inspections announced or unannounced, regarding the condition of the weapons and ammunition, as it applies to the company Fire Arms policy. Weapons not in optimum safe operating condition should not be allowed until the necessary corrections are made.

Author’s Note

This Firearms Policy is only to be used as a sample in formulating a corporate Firearms Policy. It is not to be construed as a legally written document or to be the legal authority of the author, as the author assumes no legal responsibility for its contents or any  conclusions arrived due to the approval, enactment or enforcement of the contents herein.  The author suggests that the policy, or any part of the policy, be approved by the corporate legal authority, before being enacted as company policy.

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The financial industry has the most critical need for rapid continuation of essential functions. Referred to as T-Time, two days is the maximum length of time a financial institution can effectively survive with non-productive data processing. After this T-Time has elapsed, the effects of loss of business and public confidence can negatively impact the institutions image and long term growth.

A disaster is any event which leaves the corporation in a non-productive mode. Consequently, the procedures for recovery should be written for the most probable serious occurrence. Events of lesser magnitude can be handled at the appropriate levels.

For planning purposes, it should be assumed that most disasters considered likely will occur with very little warning, have rapid development and have the potential for substantial destruction. A disaster does not necessarily start with a large impressive event. A small, localized fire can disrupt total operations.  The harm could be from water and smoke or essential equipment could be damaged or the power supply disrupted.

The principal concern at the time of the disaster is the safety and well being of the personnel involved. The principle business concern is the maintaining of accounting records. Other concerns are to minimize the disruption of services and daily business.

The disaster may be grouped in one of two major types, that being:

• A NATURAL DISASTER
• Floods, tornadoes, earthquakes, winter storms and hurricanes, etc.
• A MAN MADE DISASTER
• Fires, riots, strikes, sabotage, war and bomb threats, etc.

In order to assure the disaster recovery plan is effective and current, constant review and audits are necessary. As changes occur in the corporate structure, reporting requirements and personnel, the disaster recovery plan should be reviewed and updated accordingly. Periodic test at the designated site and “dry runs” are essential to determine system compatibility and recovery plan effectiveness.

To compliment any disaster plan. It is very important that corporation have a good comprehensive “Disaster Recovery Manual”.

The purpose of this manual is to provide the corporations Disaster Recovery teams with a formal outline of the task required to activate the phases of Disaster Recovery and to ensure the corporation has the ability and planning to recover from a disaster while minimizing the effects on a daily basis.

And, the objective of such a manual is to provide procedures for responding to a disaster that disrupts the operation of the corporation. After declaring a disaster, the plan is to restore critical applications to a reasonable service level within 24 hours.

 The Disaster Recovery Manual should include guidelines for:

• Recovery
• Event-notification
• Activation
• Mobilization
• Alternate site processing.

The Disaster Recovery Manual should also include the following agenda:

• The Command Center location.
• The alternate Command Center location.
•  Personnel Notification Guidelines
•  Fire and Police Emergency Contact Numbers
•  Personnel Emergency Contact Numbers.
•  An Organization Chart or Chain of Command.
•  Individual Assignments and Duties
•  Emergency Food and Drink Vendor Contact List.
•  Supply and Contract Vendor Contact List
•  Individual Department Supply Inventories
•  A Pre-Arranged  Special Equipment Location

The Disaster Recovery Manual should include the following representatives:

• The Disaster Recovery Coordinator.
• The Disaster Recovery Director.
• Clerical Support.
• The Internal Audit Representative.
• The Property Representative.
• The Supplies Representative.
• The Legal and Insurance representative.
• The Transportation Representative.
• The Security Director.
• The Public Relations Representative.
• The Telecommunications representative.
• The Productions Representative.

ASSUMPTIONS-CONCLUSIONS

• Operation’s contingency plans are necessary regardless of the probability of a disastrous event.
• The most common disastrous events occur during a time when the facility(s) are empty or at minimum staffing decreasing possible personnel loss.
• The probability of a disastrous event disrupting operations at the main headquarters and other branch locations simultaneously is a remote possibility.
• Disaster mode processing should include only the most critical applications relating to business operations, reporting requirements, and legally binding service agreements.
• During the critical times that follow a disaster, the effected personnel should be expected to temporally relocate and perform duties assigned and work as a team.

Remember; do not give messages regarding a disaster to anyone except individual Disaster Team members. This will help avoid inadvertent notification of disaster casualties and premature notification to the press.

Under no conditions should anyone make a statement to the news media except the Public Relations Representative.

 (Please Note: For assistance in formulating a Disaster Recovery Manual, or any other security subject help, please email this author.)

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So, what is a bank courier and what do they transport?  Simply put, a bank courier is defined as any bank employee transporting in their possession non-negotiable bank property from one point to another. Usually from the banking branches to the banks processing center. So, let us review the bank courier security in a little more detail.

COURIER DELIVERIES

Proof work, special deliveries and branch supplies should be transported in secure fire resistance containers.

CONTRACT SERVICE

Where practical, the above mentioned items should be transferred by banking in-house personnel. When such service is not available or is not cost effective, a contract service can be utilized. In this event, the banking legal authority should draft a very specific contract, in protection of the bank, specifying that the contract service be responsible for any recovery cost, if document reconstruction is necessary.

 COURIER EMPLOYEE SECURITY

• When possible, couriers should park at a location where the vehicle can be observed from within.
• Courier vehicle doors should be locked at all times whether parked, moving, vacant or occupied.
• Couriers should always be on the lookout for suspicious situations. Especially, when the same vehicle is observed over and over.
• If the courier feels followed, the courier should continue past the next scheduled stop to a safe location and notify the police.
• The courier should not stop, for any reason, while in route to or from a location, except for an emergency.

 VEHICLE SECURITY

• All vehicles should be unmarked.
• All vehicles, when possible, should have lockable trunks, electric door locks, audible alarm buttons on the remote key ring and fire extinguishers.
• Vans and camper shell pick-ups should have lockable rear compartments separated from the vehicle cabs.
• Private vehicles should not be used by bank employees unless approved by the bank Security Officer.

 COURIER SCHEDULING 

• Each banking location should have an updated copy of the courier schedule.
• If a courier does not arrive within a fifteen minute period after expected, the courier supervisor should be notified. The banks security manager and the police should be notified, if the delay cannot be explained.

 TRANSPORTATION

• All proof work, special deliveries and branch supplies should be transported in the vehicles locked trunk or a locked rear compartment.
• Transportation should be confined to the bank personal only, with no consideration given to so-called friends or hitch hikers.
• Couriers should not travel armed. If necessary, under special circumstances, this duty should be by an armed guard or member of the banks security department.

 CONTAINER CONSTRUCTION

• Local delivery containers should be constructed of a low impact type material such as plastic or cardboard.
• Over-the-road containers should be constructed of a high impact fire proof type material such as heavy cloth or metal,

 VEHICLE COMMUNICATION

• If the bank has a twenty-four hour alarm monitoring console, the vehicle could be equipped with two way radio devices.
• If no radio communication is available, the couriers should be equipped with cellular telephones.

Remember, even the most effective communication system is of little use if, during an emergency response, staff members cannot tell others their location. This problem can be reduced with the purchase of global positioning system (GPS) terminals. Inexpensive, small and lightweight, these terminals have become standard equipment for hikers, truck drivers, and aircraft. So, why not include the GPS tracking technology in courier transportation.

 TRAINING

• New couriers should be trained on all phases of the operation within a month of employment.
• Additional training sessions should be held at intervals no longer than six months.
• Training sessions should concentrate on the latest criminal trends against the banking courier industry.
• Banking courier security policies should always be reviewed.

 LESSONS LEARNED

Within two weeks after an attack or loss, the bank security department should analyze the occurrence and prepare a critique to include:

• Procedures that proved faulty and must be changed.
• Loss or injury resulting from failure to follow procedures.
• Successful application of procedures that resulted in the elimination of reduction of loss, prevention of injury, or apprehension of an attacker.

  PUBLIC RELATIONS

The fact that a loss or attack has occurred and the details of the occurrence should be communicated only to those who have a “need to know”, this is necessary for the protection of the loss items and to avoid customer panic. 

 CONCLUSION

Remember, there are many structural and procedural steps, most of which do not reduce efficiency or effectiveness, which will tend to deter criminal activity against the banks couriers. Ideally, these steps will be so subtle that they will not be offensive to the parties involved but so apparent that criminals will go elsewhere. Not all losses or attacks can be prevented, however, as there is no absolute defense against a determined attacker and some attacks are made by persons not rational enough to perceive the deterrents.  For these reasons all necessary steps should be taken continuously, to minimize such losses when attacks occur.

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(Is the majority of your bank investigators time spent in actually gathering facts and solving cases? Almost any fraud investigator can trace a bad check or investigate credit card fraud, but can they reach far beyond the traditional scope of fraud investigation by examining control weaknesses and emphasizing loss prevention. This innovative approach will quickly gain support of senior management by proving to be cost effective and deter crime, as an efficient fraud reporting system is utilized.)

 Someone once said, “the road to success is paved with reports”.  That old cliché certainly rings true, in today’s banking world. And, thanks to the now innovative statistical reporting systems, this process has been made a lot easier.

 So, why are reports that important? Simply put, if you as a banker don’t know what you are losing and when the losses are occurring, how can you prevent such loss? Therefore, the first phase of the reporting process must be the development of a statistical reporting system. And, in connection with this new reporting system, the bank must establish a “fraud investigation” policy.

 This policy must have the blessing of the bank’s legal staff, the audit staff and the branch banking executives. The policy should also cover the types of fraud to investigate along with the procedures to follow in conducting such investigations.

 The policy should emphasize using the criminal justice system rather than simply becoming an agent of the bank’s collection and recovery departments. This is very important, as word will surely and quickly get around, within the criminal ‘grapevine elements” that your bank will and does prosecute fraudulent criminal behavior.  

 Next, after the establishment of policy, a case filing system and a cross-index reference filing system should be developed. The object being to distinguish clearly and accurately the various types of cases investigated. This case numbering system should not only segregate the various fraud categories but also distinguish the geographic and demographic areas involved.

Here’s a simple but effective case numbering system.  The first numbering sequence should indicate the case year, the second numerical sequence should indicate the ongoing case number, the third numerical sequence should indicate the geographic area of the state and the final letter sequence should indicate the type case. For case 11-100-01-CK, 11 represents the year of the case, 100 is the ongoing case number, 01 represents the geographic area, and CK means it is a check case. In addition, the case jackets and cross-reference index cards could be color coded for quick, easy reference.

(Please note: a good computer word processing software package will do wonders for an otherwise novelist reporter.)

Once the case filing system is in place, the written report format may be developed. There again, keep this simple. You may choose to use four main reports, an investigator report, a supplementary report, a case status report, and an investigators informal notepad. Other miscellaneous reports, such as a suspect profile, photo lineup, and witness list, could be added as needed.

The case status report could contain a section designed to assist the branch banking system in identifying and tracking possible policy violations or weaknesses in control. However, this section should not be designed as a punishment but as an educational tool.

Investigators, receiving fraudulent information, from the branches in their jurisdictions, should first review the case facts, with the security department manager. If the case is denied, the denial facts should be noted on the case status report: to include a reason such as insufficient evidence or an insufficient reported loss amount. A copy of this status report should be sent to the reporting party. This additional feature will prove to be cost effective, as it will allow an investigator to separate the cases that apparently cannot be investigated and then concentrate on the workable ones.

A by-product, for the success of a fraud prevention program, is an in-house training program. The resident investigators can continuously update the branches on trends in the investigation industry and the latest criminal schemes. To include:

• verified trends- losses perpetrated against the bank
• calculated  trends- possible losses not yet realized

 One of the most important factors in any organization’s growth is proving its necessity and the worth of its staff. This can be accomplished by the unit’s monthly status report. This report should outline the investigators case categories: case activity, criminal justice activity: and loss, recovery, and prevention activity. A case worksheet should complement the status report, which gives a ready reference of all cases worked or pending.

An investigation unit will definitely forge ahead, by accurately reporting its worth. These criteria will turn an almost nonexistent fraud investigation function into one that is well recognized within the law enforcement and criminal justices circles, throughout the country. Yes, the road to success is truly paved with reports.

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The morning glory robbery got its name from the fact that it happens first thing in the morning-before the banking office is opened. Either the robber breaks into the office undetected, or hides in the office the day before and waits overnight for the members of the staff to arrive the next morning.

Morning Glory robberies   and Closing Time robberies are the most daring and most costly in the banking industry. And if you have experienced such a robbery, chances are several factors have come into play:

• The robbery has been well planned in advance.
• The robbers have staked out the location well in advance.
• There’s a chance some banking staff member was involved.

These type robberies are so devastating that the BPA (Bank Protection Act) requires all bank security plans to have a working opening and closing plan approved by the Board of Directors. In my former employment, the bank Audit Department took an active role in the opening and closing procedures by policing the procedures during the branch audits.

 MORNING OPENING PROCEDURE

The opening procedure should always be used when opening the bank each morning and at any other time the banking office is reopened if all employees left while the office was closed. And the process should always involve two employees.

(It is not feasible, within the scope of this article, to include a detailed opening procedure.  This procedure should be made a part of the bank’s overall “Master Security Plan” and should be considered confidential. All bank employees should declare this confidentiality, by a signed agreement. However, with permission of the bank, this author can assist in this policy draft)

 The following opening procedure precautions are advised, but are not mandatory:

• The number of employees having keys should be held to an absolute minimum.
• The opening inspection should be held before other employees are normally scheduled to arrive.
• All employees should be scheduled to arrive before vault opening.
• Employees should be discouraged from arriving prior to opening inspection and should be reminded that doing so endangers their safety.
• Customers should not be admitted prior to beginning of banking hours. If, however, it is necessary to admit someone, the same procedure for admitting employees should be followed.

 CLOSING PROCEDURE

The closing is similar in nature to a reversible opening procedure. First survey the lobby for suspicious persons and inspect areas, such as coupon booths, and the break room, where someone may be hiding. Then, initiate the closing procedure, as quickly as all customers have left the banking office. Remember, once all customers have left, lock all doors and do not allow customers to reenter the banking lobby.

(As in the opening procedure, it is not feasible to include a detailed opening procedure within the scope of this article. This procedure should be made a part of the bank’s overall “Master Security Plan” and should be considered confidential. All bank employees should declare this confidentiality, by a signed agreement. However, with permission of the bank, this author can assist in this policy draft)

The following precautions should be made a part of the closing procedure. The last person leaving the bank should:

• Open all blinds and curtains, including those at drive-in windows.
• Turn on all night lights not controlled at main panel or by timer or photo electric cell.
• Lock all exterior doors.

POINTS TO PONDER

• Does your financial instruction have an Opening and Closing procedure?
• If so, have the procedures ever been challenged?
• Have the procedures ever failed?
• How long have the procedures been successful?

 In my tenure, as Security Director of a major interstate bank, the bank’s opening and closing procedures were never compromised. Not like some other banks, in the same geographical area, in which severe losses were realized.

Remember, the only procedure for preventing the so-called’ morning glory” robbery is a comprehensive “opening and closing” policy. However, the policy is of no effect, unless practiced religiously on a daily basis.

And today, as never before, pressures are mounting to open the banking offices early for a number of reasons, including early meetings, customer account business, etc. So, be careful. Always know and follow the banks excepted audit and security precautions.

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Why have safety inspections? Simply put, to detect potential accident causes, so that they may be corrected.

When should a safety inspection be conducted? Without thinking, many a manager would answer by giving a specific weekly or monthly schedule date. On the contrary, how about making the safety inspections an ongoing thing, each time you walk through the garage, or ride in a truck. Although the primary reason for doing these various activities is to supervise or managed the corporation functions, they can easily be combined with routine safety inspections. And, when scheduling safety inspection meetings, consideration should always be given to shift workers.

Yes, safety is contagious and when a manager integrates the safety responsibilities of the job with other routine functions, his or her action will tend to rub off on the other employees.

SAFETY INSPECTION OBJECTIVE

This objective should include:

• Observing an ongoing safe environment by recognizing job hazards.
• Determining that employees are acting and working in a safe manner.
• Determining that all functions of the job meet or exceed all regulations
• Maintaining a productive and operational safe profitable environment

 SAFETY INSPECTION RESPONSIBILITY

The final responsibility is always the “head of the corporations “Chain of Command”, be it the company President, the Board of Directors, etc. However, this responsibility usually is handed down, through the ‘ Chain of Command”. to the local managers and supervisors. However, the senior management should always take an active interest in the working conditions at the lower levels of employment

And there should always be a check point, to ensure the safety inspections are being conduct properly, such as a corporation’s Safety Manager.

EXTERNAL SAFETY INSPECTIONS

Inspectors from the corporation’s casualty insurance company and property fire insurance should conduct inspections, on a regular basis. This is very important and if this is not being done, makes sure that it is put into place.

Aside from the professional safety education, available through these entities, there is also the possibility of getting this help “free of charge”.

 FORMAL INSPECTIONS

In addition to the “continuous” spot inspections previously mentioned, the corporation should conduct formal inspections, on a regular basis. These inspections should be well documented, as part of a progressive “loss prevention” program.

 SAFETY INSPECTION AGENDA

These safety inspections should include:

• Unsafe work practices.
• Bad housekeeping
• Fire control violations
• Electrical violations
• Health and Sanitation hazards
• Improper operation of machines, equipment and tools.
• DOT violations.
• OSHA violations.
• Worker Compensation hazards.

THE INSPECTION SAFETY REPORT

This report should include:

• A thorough and complete review of the safety inspection.
• A documented review by the department manager.
• Posting the report on the bulletin board for at least two weeks.
• Filing the report in the department safety file for at least five years.
• Receiving frequent management reviews to ensure compliance.

LESSIONS LEARNED

Within two weeks after any type safety violation, the department manager should analyze the occurrence and the response taken.  A written critique should be documented, as part of the safety file, and include:

• Procedures that proved faulty and must be changed.
• Loss or injury resulting from failure to follow procedures.
• Successful application of procedures resulting in elimination or reduction of injury.

  CONCLUDING PHILOSPHY

The corporate philosophy, regarding safety, should be well defined in the corporate policy. This policy should clearly assign the responsibility for safety to each individual. In other words, safety is a part of every employee’s job.

Safety programs can contribute positively or negatively to an operation but the bottom line is that a safe environment is just good business.  The primary goals of any company are to make a profit, protect the company’s assets and investments and remain competitive in business. And safety plays an important part in attaining these goals.

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I had the distinct privilege of being a bank security director, during these true episodes. Needless to say, this gentleman became quit famous in the banking circles.

So, how is your financial institution currently fixed to detect and prevent one of the most popular frauds against the banks, that being teller fraud.

Teller fraud causes the financial industry mega bucks each year, by deceit, trickery and swindling its customers. It may take on a number of forms such as stolen, forged or altered checks. Upon presentation to the teller, many techniques are used to distract and confuse the teller. Caution should be given when the presenter:

• Tries to divert attention from the transaction.
• Wants to skip the necessary policy and procedure.
• Appears overly sincere and honest.
• Gives a sob story.
• Threatens to make a report unless the teller does what he or she says.

Con artist usually mimic an average customer but use techniques they feel will throw the teller off guard. A person who acts in the ways described is not necessary a forger. However, the teller is usually protected by the proper policy in reporting such suspicious activity. Over time, an experienced teller just develops a “sixth sense” about such fraud attempts.

PROPER IDENTIFICATION

The teller should always be familiar with the banks guidelines to help ensure only authorized people receive bank funds, to ensure the money is given to the proper person. Once the money is given for a forged or stolen check, it is usually impossible to recover the funds. Identification is the most important tool in preventing this loss. Tellers should always:

• Compare signatures on the check with the presented ID.
• Ensure that the ID name, address and telephone number matches the check ID.
• Compare the description or photo on the ID to the presenter.

Remember, it is the teller’s responsibility to determine that signatures and endorsements on a check are authorized and genuine. Here is just s few points to ponder to ensure this:

• Forged signatures will show irregularities such as uneven or shaky handwriting.
• In improper signatures, periods following initials will normally remain in the same place.
• Writing slant is not likely to change.
• Dots over I’s and the T crossing will remain constant.
• Capital letters will remain the same.

If the teller is not sure, or senses the signature may be forged, the teller may insist that the check be endorsed again on the opposite end or examine the entire check for signs of forgery.

So, what is some fraud attempts to guard against.

SPLIT DEPOSITS

A split deposit is just that. One or more forged or worthless checks are deposited with a request to receive a portion back in cash, usually a small amount. The presenter may even use a deposit slip from the lobby and deposit a stolen check into a legitimate customers account, with a request for cash. The success of a split deposit depends on convincing the teller the depositor is a customer in good standing. Always be careful of any new account customer who uses counter deposit slips. (A new account will always have a very low check number).

AUTHORIZED FRAUD

Forgers have devised many schemes for obtaining an official signature. A forger may purchase a cashier’s check or money order for a small amount, only later to claim no use for the check and return it. The forger can then trace the officer’s approval on a worthless document. Any check presented by a customer with approval by the platform or an officer should be verified.

CHECK KITING

Check kiers take illegal advantage of various financial institutions by moving money around, like flying a kite between two or more checking accounts.  They will write checks on money that is not in the account at the time the check is written. Unless a kite is discovered early, losses can be extreme.

ALTERED CURRENCY

It is wise for the teller to be familiar with the president pictures on the various money denominations. This helps the teller recognize the altered bills. A common ploy of counterfeiters is to cut the corners from large denomination bills, then glue them to the corners of small denomination bills. A one dollar bill can be altered in this fashion to resemble a ten or twenty dollar bill.

COUNTERFEIT CURRENCY

The best method of detecting counterfeit currency is to compare the suspect bill with a genuine bill of the same denomination. Be aware of the differences, not the similarities.

TRAVELER CHECKS

Traveler checks are issued by internationally known financial organizations. They are paid for in advance and are guaranteed against loss or theft. The signature of the buyer is written on the face at the time of the purchase and there is a space provided for the purchaser’s counter signature, at the time the check is cashed.

PREFERRED CHECKS

Criminals are well aware of readily negotiable checks such as government checks, state, county, or city payroll checks, cashier’s checks, drafts and money orders. A criminal will routinely open an account with a small amount of cash and later present a preferred check in a split deposit transaction.

PLEASE NOTE:

The before mentioned fraud scheme definitions are brief in nature. For additional precautions, to guard against such schemes, consult your financial institution’s security plan or contact this author.

SUMMARY

Remember, all customer accounts and transactions are confidential, as well as any bank security policies and procedures.

Most people who approach the teller line are honest citizens, who are regular customers or are there for a legitimate purpose, even if they bank somewhere else. It is these people, whose money the teller has been entrusted to safeguard. An alert, caring teller makes the difference between being taken in by a con artist and taking care of the customer’s best interest. So, take good care of your tellers and pay them well.

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