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Latest Compliance - Record Retention Topics

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?

"Blocking" Lenders from Viewing Documents

01/17/2016

We are now scanning all of our deposit and loan documents for our customers. Is there any reason to "block" our lenders from viewing all the documents - such as a drivers license? Currently our lenders are blocked from viewing all deposit documents as well as CIF documents - signature cards, resolutions, trusts, drivers license, etc. Our lenders are required to capture the information from the drivers license when completing the loan application. I can remember back when we had loan files that we weren't allowed to keep a copy of the DL in the file. But now that they are scanned, do they need to be "blocked" from certain employees for viewing?

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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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Opening Online Acct. & Funding w/ACH Debits

06/16/2019

Our digital channel team would greatly appreciate your comments and confirmation of our understanding in order to comply with online account opening and funding for new clients with ACH Debits and the ability to hold funds. The questions below relate to an online account opening process for new clients. After completing the online application, approved clients have the option to fund their new account with funds from an external source – an account they hold at another bank - via an ACH Debit and we are the ODFI. 1. Can we place a hold on the initial funds received as an ACH Debit? Our understanding is “yes” because: · an ACH debit does not fall under the definition of an electronic payment under Reg. CC (II.Section229.2 Definitions (p)) Electronic Payment, which imposes no availability requirement, and we are free to hold the funds for a period that we determine. Restricting access to those funds would be reasonable to allow for the debit entry to reach the RDFI and be returned to our bank, the ODFI, if there is a problem. · We are not receiving an ACH credit as we are the ODFI of the ACH debit, and NACHA has no say in when we credit the new account, so there would be no violation of NACHA rules.</ul> 2. Would we be required to provide a hold notice to our online account applicant of the delay in availability or a notice at the time the external funding option is selected that the funds may not be credited to the account for “2-3 days”, or available for “2-3 days” suffice? Our understanding is: · a notice that indicates funds may not be available for x days at the time the customer selects the external funding option and submits their authorization should suffice as it becomes part of our agreement when the customer selects that funding option. · Reg. CC does not impose an availability requirement for ACH Debit transactions, so no Reg. CC hold notice is required. 3. Would our Reg. CC Policy – Funds Availability Notice, need to be updated to refer to availability from ACH Debit transactions? · Model language is silent in this regard, any recommendations or suggestions are welcome.

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