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#2188618 - 08/09/18 07:10 PM Electronic Retention
JC Offline
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Joined: Jan 2014
Posts: 147
Oklahoma
I am reviewing our Online Banking and Mobile Banking electronic retention process. Can anyone share with me what you do in this space from a compliance perspective or do you rely on your IT, IS teams for monitoring?

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eBanking / Technology
#2188827 - 08/11/18 12:54 PM Re: Electronic Retention JC
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
From an audit perspective? Record retention should be tested as part of any full scope audit. You select a sample of the records or documents that you are concerned about for retention periods and ask them to provide the records.
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#2190426 - 08/23/18 08:48 PM Re: Electronic Retention JC
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Compliance should either test it, or verify the work of IT. What has to be retained, for how long, and what is a part of your mobile operation which falls in this category?

I recall many years ago when I used a compression program to backup and archive my audit reports. The first time I needed a backed up file I learned the program was carp and I really couldn't get to what I needed.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#2190453 - 08/24/18 01:53 AM Re: Electronic Retention JC
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
I agree with this advice, but the term "Online Banking and Mobile Banking electronic retention process" doesn't tell me what kinds of records we're talking about. If they include the detailed information you would need to resolve EFT or credit card errors under Regs. E and Z, for example, then you have a major interest in the reliability of the system. Likewise, if this category of records holds your only evidence of proper consent under ESIGN, then you must be very interested.
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