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#1608217 - 09/23/11 08:10 PM Complaint Retention
TMatt87 Offline
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TMatt87
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Idaho
We are a FDIC regulated bank, and my folder with consumer complaints and our responses is overflowing. How long does the FDIC require banks to retain records of consumer complaints?
Thanks!
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#1608363 - 09/26/11 11:03 AM Re: Complaint Retention TMatt87
Retired DQ Offline
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Turnpike Exit 10
Can you scan them? We do.

I would hold them from examination period to examination period.
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#1608478 - 09/26/11 02:43 PM Re: Complaint Retention Retired DQ
TMatt87 Offline
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TMatt87
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Idaho
We could scan them, but my boss likes hard copies. Is there any regulation or guidance that states how long you have to retain the complaints?
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#1608544 - 09/26/11 03:35 PM Re: Complaint Retention TMatt87
waldensouth Offline
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FINALLY ABOVE the gnat line
If it involves an error, then the reg. that deals with that error - i.e. Reg. E - will have a retention requirement. Otherwise there is no regulatory requirements for retention of general complaints that I am aware of - other than keeping them until the next examination.

You probably need to look beyond the reg. retention date and look at the limitations on liability - what is the farthest out that you can be sued for this if the customer doesn't like your answer.
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#1608629 - 09/26/11 04:55 PM Re: Complaint Retention waldensouth
TMatt87 Offline
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TMatt87
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Idaho
Thank you both!
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#1608762 - 09/26/11 07:03 PM Re: Complaint Retention TMatt87
Rocky P Offline
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Florida
TMatt, you mentioned in the original post that your folder runneth over. Many banks get a lot of inquiries, or questions about . . . . . etc, but only a few of those seen to be true complaints.

Might the bank be too harsh on itself in defining a complaint?
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#1608977 - 09/26/11 09:39 PM Re: Complaint Retention Rocky P
TMatt87 Offline
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TMatt87
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Idaho
All the ones in the folder are official complaints sent through the state or the better business bureau. We have saved all of them for as long as I can remember just in case legal action is taken. I have been looking on the FDIC website to see if they have any retention requirements but haven't had any luck so far.
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#1610682 - 09/29/11 05:32 PM Re: Complaint Retention TMatt87
NU Rhules Offline
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SE, Nebraska
I found this at the Fed: Not dated and can't really tell the context from which page this linked. Anyway, their policy (assume based on law) is 5 years.
http://www.federalreserve.gov/files/pia_ccis.pdf

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#1911067 - 04/02/14 09:04 PM Re: Complaint Retention TMatt87
Sgt. Pepper Offline
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Massachusetts
I wanted to revive this thread because I think it is important. The FRB link that Cornhusker posted is no longer working, but here is the current link:

http://www.federalreserve.gov/files/pia-ccis.pdf

The link above appears to deal with the FRB's official complaint management portal, similar to what the FDIC does via FDICConnect.

By the way, it appears that the FDIC also keeps complaints for a period of 5 years based on this document that has the FDIC's record retention schedule (go to PDF Page 45):

http://www.archives.gov/records-mgmt/rcs...7-001_sf115.pdf

I think that I am going to start keeping non-Reg. E complaints for 5 years based on this information.
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