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#531716 - 04/13/06 06:49 PM Record Retention
CrashDavis Offline
Gold Star
Joined: Jun 2005
Posts: 283
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.

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#531717 - 04/21/06 03:31 AM Re: Record Retention
rlcarey Online
10K Club
Joined: Jul 2001
Posts: 80,358
Galveston, TX
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.
The opinions expressed here should not be construed to be those of my employer:

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#531718 - 04/21/06 06:42 AM Re: Record Retention
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
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.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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