A customer closes an account. How long does your bank keep that individual’s CIP information; i.e. name, address, DOB, and SSN on your computer system? Due diligence information; e.g. occupation, employer, income, etc.? ( BSA would only require a bank to keep the CIP information and then for only five years after the account was closed. It would not require that the information currently be available on the computer system, just that the bank be able to produce it within a reasonable period of time.)

Clearly, keeping the information longer could be a convenience to the bank; e.g. if the individual returns at some future date and opens an account. Even then, the CIP regulation would still require the bank to verify the CIP information. (The exception to the requirement for verifying information is when an individual has an existing account, not a closed account.)

On the other hand, consumers might prefer that their information be expunged from the records of a bank with which they no longer do business. There could also be latent issues if a bank’s records link customers opening a new account to one another; e.g. former spouses, relying on a connection that no longer exists.

Due to an unusual set of circumstances, I recently opened two bank accounts in a seven-day period. One bank summoned up information from an account I closed in 2006. The other, from an account I closed in the previous century; i.e. 1999. I was surprised...

Section 500.13 Limitations on Data Retention.
As part of its cybersecurity program, each Covered Entity shall include policies and procedures for the secure disposal on a periodic basis of any Nonpublic Information identified in section 500.01(g)(2)-(3) of this Part that is no longer necessary for business operations or for other legitimate business purposes of the Covered Entity, except where such information is otherwise required to be retained by law or regulation, or where targeted disposal is not reasonably feasible due to the manner in which the information is maintained.

https://www.dfs.ny.gov/legal/regulations/adoptions/dfsrf500txt.pdf

We are a NYS FI and have to follow this.

Thank you. That is very helpful.

Anyone else?

We purge closed accounts from our system after a period of time, but we do not purge customer information.

Same here, accounts purge, people stay (in the system).

Closed accounts purge from the system after 3 years and closed CIFs purge after 5 years. All hard copies are destroyed after 5 years.