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#1469043 - 11/17/10 04:59 PM Risk review record retention?
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
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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rlcarey
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.
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