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#1136190 - 02/26/09 12:47 AM Record Retention - NSLs?
DebL Offline
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FDIC Examiners are here and asking how long we retain our NSLs. Our policy calls for 5 years, but he said we should be keeping them for 7. I looked in the BSA Exam Manual in the record retention section and used the index to see where else they appear, but no luck on finding anything on retention.

Any help would be appreciated!
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#1136631 - 02/26/09 05:34 PM Re: Record Retention - NSLs? DebL
MagicCity Offline

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I could not find anything on this either...
Anyone know?

Can you ask your FDIC examiner for the source...?

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#1136726 - 02/26/09 06:56 PM Re: Record Retention - NSLs? MagicCity
Hrothgar Geiger Offline
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The question that comes to my mind is whether the examiner would be allowed to see or handle an NSL during the exam....

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#1136760 - 02/26/09 07:17 PM Re: Record Retention - NSLs? Hrothgar Geiger
MagicCity Offline

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He would not be.
I assume he is reviewing their policy.

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#1138128 - 03/02/09 01:21 PM Re: Record Retention - NSLs? DebL
Elwood P. Dowd Offline
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Whatever sources NSL compliance standards might be derived from, it's not the Bank Secrecy Act.

If your examiner thinks its 7 years then he or she should be able to support that position with a citation. Ask for it.
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#1138600 - 03/02/09 09:26 PM Re: Record Retention - NSLs? Elwood P. Dowd
DebL Offline
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I will certainly ask him.
Thanks for the input!

(He didn't ask to see any NSLs. As MagicCity said, he was just looking at our policies & procedures.)
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#1138767 - 03/03/09 02:20 PM Re: Record Retention - NSLs? DebL
Hrothgar Geiger Offline
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Section 505 of the USA PATRIOT Act is the relevant section for NSL's. I might have missed it, but didn't see any reference to document retention.

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#1140141 - 03/04/09 09:57 PM Re: Record Retention - NSLs? Hrothgar Geiger
DebL Offline
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Joined: Jan 2007
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Thanks for checking. After I asked him for a cite, he dropped it!

I hate it when they make things up as they go along!!!
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