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#199239 - 06/10/04 08:34 PM Record Retention

Anyone knows what is the retention period on tax returns on a credit file? We require a yearly copy of tax return on our commercial line of credit. If the line were open for 20 years we would have 20 years of tax return for that specific customer. If we only keep the last 10-year would we get in trouble with any Auditor or bank examiners?

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#199240 - 06/14/04 02:08 PM Re: Record Retention
complyguy Offline
Gold Star
Joined: May 2001
Posts: 494
This answer will not be helpful. Record retention is another one of those topics that gets beaten to death in the PA forum. Some folks have "store bought" reference materials, while some of us have, umm, slightly dated references from PA banking associations. They rarely match item for item. In fact, they usually don't describe or group items the same way.

Like a good source for PA banking laws (of which record retention is a subset), an authoritative source for PA record retention is elusive.

I would be delighted to be proven wrong by someone who has a link to an authoritative source that is clear & easy to use. Anyone?

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#199241 - 06/14/04 09:18 PM Re: Record Retention

I do not think credit file information is subject to any legal record retention schedule in PA. This would be a bank policy issue. Our bank policy is to keep three (3) years of income tax returns in the credit file, any tax return information older than this would have minimal value. We have never been criticized by auditor or regulator regarding this issue.

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#199242 - 06/15/04 12:23 PM Re: Record Retention
DebNP Offline
100 Club
Joined: Oct 2001
Posts: 179
Eastern PA and NJ
ComplyGuy, you are correct, retention schedules in PA, is one of those things that is never clear cut, and there are many versions of retention. I too have never found one that is clear and too the point. If anyone is interested, I do have a 1990 (it is old!) version of PBA's retention schedule I got a seminar. (send me a PM and I am willing to share what I have). In one section, it even mentions "ledger cards", now how old is that! Unless, you have been in banking a long time, you may not remember some of the old processes. Credit files are listed as 10 years after closing. Tax returns are not specifically listed. One rule of thumb, I picked up (at a PBA seminar, I think) is if unsure, ask yourself the question of whether you would need anything from that file for BSA purposes - and if so, keep it 5-7 years. Hope this helps.

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