What are the specific requirements for record retention for CIP purposes? From what I heard was:

*Account Opening documents - 5 yrs after account is openend.
*Signature Cards - 5 yrs after account is closed.

Can someone please clarify this for me? I want to make sure we are keeping what we need to for the specified amount of time.

thanks!!!!

The basic information (name, address, DOB and ID number) must be kept for 5 years after closing the account. The documentary and nondocumentary verification information and the resolution of any discrepancies must be kept for 5 years after the account is opened. So it's the information that must be retained for CIP, not the specific documents. Those other documents might need to be retained for other reasons.

So, in essence we could keep all of our account opening documents (New Account forms, etc) for 5 yrs after the account is opened. But must keep the signature cards (because they have name, address, DOB & ID #) for 5 yrs after the account is closed.

The girls were just wondering if they would have to keep all the new account forms for 5 yrs after the account is closed, but that seems to be not the case. Correct?

Many bank systems have that initial account opening information stored in file maintenance that is preserved for the required time period. That initial information never changes. New file maintenance records with later dates are created as account info is updated. Some banks utilize that initial file maintenance as the official BSA retention for the name, address, DOB, ID# rather than duplicating stored data.

Correct. Only the "big four" pieces of information have to be kept that long, however you choose to keep them.

One area to be aware of - if your customer changes his or her address, are you archiving the original address from when the account was opened? Because technically that's what is required.

I know it would seem a bit moot to have an address that hasn't been the customer's address for, say, over 10 years, but I could see this as a potential exam "gotcha."