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#2273132 - 07/20/22 06:30 PM Record Retention of Periodic Bank Statements
Bankwoman1 Offline
Platinum Poster
Joined: Dec 2015
Posts: 954
Midwest
How long should a FI in Indiana keep copies of customer bank statements? Some in the bank say 5 years, some say 7 years. When I look at Reg DD requirements, it states 2 years. So now I am really confused.

I'm not seeing anything in state code (at least I can't find it).

Can anyone help me out with this?

Thanks!

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#2273143 - 07/20/22 07:10 PM Re: Record Retention of Periodic Bank Statements Bankwoman1
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 954
Midwest
Ok....I think I found what I was looking for within the Bank Secrecy Act:

Each statement, ledger card, or other record on each deposit or share account showing each transaction in or with respect to that account, such as a monthly statement.

All records must be retained for a period of five years....

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#2273282 - 07/22/22 04:58 PM Re: Record Retention of Periodic Bank Statements Bankwoman1
dshuff Offline
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dshuff
Joined: Jun 2007
Posts: 33
Ohio
Did you find this in the BSA regulation, or do you have an Indiana document retention schedule?

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#2273288 - 07/22/22 05:38 PM Re: Record Retention of Periodic Bank Statements Bankwoman1
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 954
Midwest
I found the above in the BSA regulation. I also spoke with one of our external reviewers who stated it is covered under state law. However, the only information he was able to find in the state code discussed 3 years and did not directly mention periodic statements. So we determined that going with 5 years was a safe bet.

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#2273292 - 07/22/22 06:00 PM Re: Record Retention of Periodic Bank Statements Bankwoman1
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,391
Galveston, TX
Talk to your legal counsel. How long can a customer bring suit against the bank in Indiana. This is not a BSA issue.

Well, I guess should add - unless the statute of limitation on any lawsuit in which such records would be required to be retained for bank defense purposes was less than 5 years.
Last edited by rlcarey; 07/22/22 06:16 PM. Reason: added comment
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#2273329 - 07/25/22 02:22 PM Re: Record Retention of Periodic Bank Statements Bankwoman1
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,030
Bloomington, IN
Not absolute but a starting point reference: https://www.findlaw.com/state/indiana-law/indiana-civil-statute-of-limitations-laws.html

As Randy stated however you should follow your legal counsel advice.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2273331 - 07/25/22 02:47 PM Re: Record Retention of Periodic Bank Statements Bankwoman1
Bankwoman1 Offline
Platinum Poster
Joined: Dec 2015
Posts: 954
Midwest
Dan and Randy, thank you both for your help with this!

FYI....I asked our outside auditor and our bank attorney and they both stated that we should be safe with 5 years. However, after looking at the Indiana Code and the link you sent above, I did find information stating the statute of limitations is 6 years (at least from what my non-attorney brain understood). So, I have talked with our operations department and we have decided to go with 7 years to be safe!

Some days I feel like I need a law degree to understand my job........

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