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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.

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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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Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

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