Is there another Nicola user out there that can help me understand how to review our archived CIFs for the last 5 years. The recent FinCEN's instructions require us to review our CIF's for the past five years. Nicola, after 13 months moves the CIF of the closed account to their archives. We are having an issue trying to pull those archived CIFs to compare to the 5 year requirement by FinCEN. Any help would be appreciated!

What instructions are you referring to about the requirement to review the CIFs for the past five years? We keep all of ours (so far, forever), but don't review them again once the initial review is done.

Granny is referring to 02/21/11's 314a search.

We are not a Nicola Banking User, but we had the same problem. We resolved it by using our Imaging system to do a name search (yes one at a time!!)on all documents for the past 5 years. I utilized a branch person that was not that busy to search for me. It took her 2 days (with doing her other work). Whatever your imaging process is may give you the same capabilities.

I ama sure if probably is a requirement but I certainly would like to review the reg based on the time it will take to review.

Does anyone have the section that allows the FINCEN to go back this far.

Retention may be 5 years but this is quite a burden!