What are you wanting a program for? The loan function or the imaging piece? Retention in many cases is driven by specific regulations and state law and needs to be implemented by management. Depending on what areas you are auditing, you'll need to reference those particular regs and then the laws of your state, then review your bank's rentention policy and make your comments accordingly. You might start with Auditnet.org for your audit programs. They have an extensive list.