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#2255835 - 06/23/21 07:21 PM Transitioning to Digital and Hardcopy Retentions
LauraLinB Offline
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Joined: Jul 2018
Posts: 12
Hello!

We are in the process of moving paper documents within customer files to digital and there is the question of whether or not we need to keep the paper documents once they've been scanned digitally. Does anyone have any experience or best practices with regards to this? Thanks!

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BSA/AML/CIP/OFAC Forum
#2255839 - 06/23/21 07:35 PM Re: Transitioning to Digital and Hardcopy Retentions LauraLinB
praBSA Offline
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Joined: Aug 2018
Posts: 258
Knowing what type of documents would be key here. Personally, we shred everything except original signature cards once everything is scanned in.

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#2255844 - 06/23/21 07:44 PM Re: Transitioning to Digital and Hardcopy Retentions praBSA
LauraLinB Offline
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Joined: Jul 2018
Posts: 12
Primarily we are looking at CIP documents, but also various account maintenance forms as well. Our current deposit origination platform is digital, signature cards are signed and stored electronically, removing the need for a printed document with a wet signature.

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#2255845 - 06/23/21 07:47 PM Re: Transitioning to Digital and Hardcopy Retentions LauraLinB
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 5,977
Illinois
Any requirements for physical documents would be a matter of state law. BSA record retention merely says that required records must be "retrievable." Whether you store then via physical copy, microfilm, microfiche, computer magnetic tape, or digital image is up to you.
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#2255846 - 06/23/21 07:47 PM Re: Transitioning to Digital and Hardcopy Retentions LauraLinB
praBSA Offline
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Joined: Aug 2018
Posts: 258
I don't ever recall anything specifically about needing physical copies of any particular documents for BSA purposes. Someone can correct me if I'm wrong on that.

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#2255872 - 06/23/21 09:50 PM Re: Transitioning to Digital and Hardcopy Retentions LauraLinB
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,950
New York City
Two things are in play here. Brian nailed the first in what the record retention rule requires. The second is what your Board approved AML Policy requires.
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#2255940 - 06/25/21 01:39 PM Re: Transitioning to Digital and Hardcopy Retentions LauraLinB
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,987
Toano, VA
State statutory laws may not spell it out clearly, but case law is what really matters. Ask the bank's attorney what bank records (if any) MUST be in paper form in order for the bank to prevail in any litigation with customers.
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