I have a question regarding record retention of policies and forms. When we change the BSA policy or forms, how long should we keep the old policy in a file? Is it necessary to keep these policies once the policies have changed?

I am referring to BSA Policies and Procedures and also blank Monetary Instrument Logs.

Thanks for your assistance.

The approved BSA policies and procedures, since they are required to be board approved, should remain as exhibits to the minutes and would require permanent retention.

Monetary logs - no.

Many companies, not just banks, retain files of prior policies and procedures as a historical record. It is a good practice. Sometimes policies and procedures from several years ago are needed to resolve a question or as evidence in a court case. They are a corporate record. Yes, they should be maintained with the board records. But the BSA area should retain a copy of all prior policies and procedures.