Please take a look at the post Andy added to the linked thread a few months later. The OCC guidance suggests a couple of approaches that do not involve keeping the lists - if you are a National bank, you're home free if you take one of those. If you are Fed or FDIC, you might call the EIC from your last exam and ask if one the approaches outlined there would be acceptable.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.