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Latest Compliance - Record Retention Topics

FDIC Quarterly Banking Profile Book Retention

02/09/2020

I just found a hoard of FDIC Quarterly Banking Profile books. I am assuming that we have kept these over the years because no one knew how long to keep them. As a rule of thumb, I have been keeping things that I am unsure of for at least 5 years. I have not found something in my department that has to be kept any longer tan that. I could not find any record retention guidance for this book. Should I trust my gut and just keep 5 years worth?

State Specific Record Retention Schedule

01/27/2019

We are working on our record retention schedule and were wondering if there is a record retention schedule for the state of Oklahoma that we need to be incorporating into ours?

Record Retention Period for MC Account Number?

08/26/2018

Is there a Record Retention Period for a MasterCard Account Number on file? We are the issuer of the card and the Bank continues to hold the account number on file even when it has expired. Do the same rules​,​ if any, apply for VISA?

Retention of Physical Deposit Hold Notices-Reg CC

02/05/2017

What is your view on retention of the physical deposit hold notices​ to meet Reg CC retention requirements? We recently converted our core system​ and have the opportunity to electronically record data used to populate​ deposit hold notices rather than retaining the physical forms.The data will​ be in the form of a report rather than a customer view of the notice.​ Parameters are set in the system for hold types, hold days, and makes consideration for multiple hold scenarios such as large deposit hold for​ amount over $5,000, two day availability for $4,800, and next day for $200.There is also a required field for facts to support reasonable cause holds​ when confidential information is selected.

Record Retention: Secondary Market Loans

02/14/2016

We are an electronic filing bank. All of our documents are scanned in and hard copies then shredded. On an MPF file (loans that are Secondary Market loans), how long do we need to keep the file once the loan has been sold/paid off?

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Board Approval for Policies

Question: Does the Board need to approve our record retention policy as well as our record retention schedule?

Record Retention of Audit Work Papers

Question: What is the record retention period for audit work papers?

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Threshold for Regulation Z Coverage (Non-RE Loans)

02/16/2020

Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.

CRA Changes for Intermediate Small Banks

02/16/2020

Our bank is an Intermediate Small Bank under the current CRA rule, with an asset size of $750 million. Will we still be treated differently from large banks under the proposed rule?

TILA Disclosures Given to Business Entity (Reg Z)

02/16/2020

If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?

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