FR4004_20190828_omb

Supporting Statement for the
Written Security Program for State Member Banks
(FR 4004; OMB No. 7100-0112)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years,
without revision, the Written Security Program for State Member Banks (FR 4004; OMB
No. 7100-0112). This information collection arises from a recordkeeping requirement contained
in section 208.61 of the Board’s Regulation H - Membership of State Banking Institutions in the
Federal Reserve System (12 CFR 208), which requires each state member bank to develop and
maintain a written security program for the bank’s main office and branches within 180 days of
becoming a member of the Federal Reserve System.
The estimated total annual burden for the FR 4004 is 26 hours. There is no formal
reporting form for this collection of information (the FR 4004 designation is for internal
purposes only), and the information is not submitted to the Federal Reserve System.
Background and Justification
Section 3 of the Bank Protection Act of 1968, as amended,1 requires the Board to
promulgate rules establishing minimum standards for state member banks regarding the
installation, maintenance, and operation of security devices and the maintenance of procedures to
discourage robberies, burglaries, and larcenies and to assist in the identification and
apprehension of persons who commit such acts. Section 208.61 of the Board’s Regulation H
implements this statutory provision and requires state member banks to adopt a written security
program, designate a security officer who administers the security program, and maintain certain
security devices. The requirements of section 208.61 of Regulation H, including the required
contents of the written security program discussed below, were developed following extensive
consultation with the banking community, law enforcement officials, insurance representatives,
security equipment specialists, and the other federal banking regulatory agencies regarding the
minimum standards needed to deter crimes against financial institutions and assist in the
apprehension of perpetrators of such crimes.
Description of Information Collection
Each state member bank must keep a written security program. The program must be
developed by a security officer designated by the bank’s board of directors. This program must
establish procedures for opening and closing for business and for the safekeeping of all currency,
negotiable securities, and similar valuables; establish procedures that will assist in identifying
persons committing crimes against the institution and that will preserve evidence that may aid in
their identification and prosecution; provide for initial and periodic security training of officers
and employees in their responsibilities under the security program and in proper employee
conduct during and after a burglary, robbery, or larceny; and provide for selecting, testing,
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12 U.S.C. § 1882.

operating, and maintaining appropriate security devices.
Time Schedule for Information Collection
A state member bank must implement a written security program within 180 days of
becoming a member of the Federal Reserve System. The written security program is a
recordkeeping requirement, and copies of the program are not collected by the Federal Reserve
System or published. Bank examiners verify compliance with this recordkeeping requirement
during examinations of state member banks.
Legal Status
The FR 4004 recordkeeping requirement is authorized by section 3 of the Bank
Protection Act of 1968, which requires federal banking agencies to issue rules establishing
minimum standards for banks with respect to the installation, maintenance, and operation of
security devices and procedures to discourage robberies, burglaries, and larcenies and to assist in
the identification and apprehension of persons who commit such acts (12 U.S.C. § 1882(a)). The
FR 4004 is mandatory.
Because there is no reporting requirement associated with this recordkeeping
requirement, the issue of confidentiality does not normally arise. If a bank’s written security
program were retained during the course of an examination, it would be exempt from disclosure
under exemption 8 of the Freedom of Information Act (FOIA), which protects bank examination
material (5 U.S.C. § 552(b)(8)). In addition, the records may also be exempt from disclosure
under exemption 4 of the FOIA, which protects from disclosure “trade secrets and commercial or
financial information obtained from a person and privileged or confidential” (5 U.S.C. §
552(b)(4).)
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On April 19, 2019, the Board published an initial notice in the Federal Register
(84 FR 16492) requesting public comment for 60 days on the extension, without revision, of the
FR 4004. The comment period for this notice expired on June 18, 2019. The Board did not
receive any comments. On August 13, 2019, the Board published a final notice in the Federal
Register (84 FR 40054).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 4004 is
26 hours. The estimated number of respondents is based on the average number of state member
bank applications approved annually during the calendar years 2015 through 2017.

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The Board believes that it is usual and customary for a state member bank to maintain a
written security program. Therefore, it has excluded the time and financial resources necessary to
create such a program from its estimated average burden for the FR 4004.2 The Board estimates
that, because of the specific requirements of section 208.61 of Regulation H, a new state member
bank will, on average, require 1 hour to revise a written security program that is compliant with
the particular requirements of that section than would be usual and customary in the creation of a
written security program. The Board estimates that an existing state member bank would not
incur any additional ongoing recordkeeping burden to keep the records required by section
208.61 of Regulation H beyond what is usual and customary to maintain a written security
program. These recordkeeping requirements represent less than 1 percent of the Board’s total
paperwork burden.

FR 4004
Section 208.61

Estimated
number of
respondents3

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

26

1

1

26

The estimated total annual cost to the public for this information collection is $1,498.4
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System is minimal because there are no
reporting forms, and the information is not submitted to the Federal Reserve.

2

5 CFR 1320.3(b)(2).
Of these respondents, an average of 18 (based on the past three calendar years) are considered small entities as
defined by the Small Business Administration (i.e., entities with less than $550 million in total assets),
https://www.sba.gov/document/support--table-size-standards. There are no special accommodations given to
mitigate the burden on small institutions.
4
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $19, 45% Financial Managers at
$71, 15% Lawyers at $69, and 10% Chief Executives at $96). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2018, published March 29, 2019, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Occupational Classification System, https://www.bls.gov/soc/.
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