Signature Card Retention Requirements Answer by: Ken Golliher, BOL Guru BIO AND CONTACT INFO
Question: We have recently begun imaging and storing account signature cards on a document retrieval system. Once verification steps have been followed to ensure a quality image has been captured, original signature cards are "bulk stored" in an off-site warehouse. Question: does image storage replace the need to retain original signature cards? If not, what are the requirements to ensure that original documents are properly maintained and retained by a financial institution?
Answer: Hopefully, half an answer is better than none. Federal law (Bank Secrecy Act regulations) requires that you be able to reproduce the card for five years after the account is closed, but indicates your copies are adequate:
31 CFR 103.34 (b) Each bank shall, in addition, retain either the original or a microfilm or other copy or reproduction of each of the following:
(1) Each document granting signature authority over each deposit or share account, including any notations, if such are normally made, of specific identifying information verifying the identity of the signer (such as a driver's license number or credit card number);
However, you also need to get the method "blessed" according to the law of your state. Call your state banking association or state department of banking (even if you are a national bank) and ask for a copy of a record retention schedule.
Also critical is any statute your state may have regarding the admissibility of copies in court proceedings.
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