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#1469043 - 11/17/10 04:59 PM Risk review record retention?
NotDoneYet Offline
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Joined: Jul 2010
Posts: 482
I do monthly, quarterly and annual risk reviews depending on whether the customer is high, moderate or low risk. Has anyone determined how long these records should be retained? I am not referring to anything dealing with SARs.
On one hand, I am thinking from exam to exam to prove it is being done per bank policy. On the other, since it is BSA/AML related should it be 5 yrs? That could mean storing a lot of paper files.
Thanks for any input.

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#1469224 - 11/17/10 07:29 PM Re: Risk review record retention? NotDoneYet
rlcarey Online
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Joined: Jul 2001
Posts: 77,247
Galveston, TX
I would not keep them for 5 years as risk reviews are not part of the regulatory framework - only the pseudo framework created by the regulators. I would recommend at least audit to audit and maybe a little longer as you may need to refer back to them for information when conducting subsequent reviews.
The opinions expressed here should not be construed to be those of my employer:

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