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#781390 - 07/24/07 02:28 PM Retention of Documents
Oviedo Boy Offline
Platinum Poster
Joined: May 2006
Posts: 629
Tennessee
In reviewing the doc package we provide for new checking accounts, it appears we produce the following:

Signature Card
EFT Disclosure
TIS
Funds Availability
Schedule of Fees
Notice Regarding the Pmt of Items (we pay largest items first)
Privacy Notice

I was wondering what documents we are required to keep. We are going to start scanning all documents, but I don't want to scan anything we don't need to keep. Or, is it safer just to scan everything? Thanks!
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Operations Compliance
#781822 - 07/24/07 07:25 PM Re: Retention of Documents Oviedo Boy
BeachGirl Offline
100 Club
Joined: Sep 2001
Posts: 206
Myrtle Beach, SC
I would scan only the signature card. One copy of the disclosures should be maintained so that you can reproduce it if requested by a customer. I keep a retention file that includes each version of these disclosures as they are changed. For example: we usually change our schedule of fees in January each year. I keep one for each year so that I can reproduce it if necessary or at least refer to it if questioned.
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#781899 - 07/24/07 08:09 PM Re: Retention of Documents BeachGirl
Oviedo Boy Offline
Platinum Poster
Joined: May 2006
Posts: 629
Tennessee
What if the Branch gets the customer to sign the EFT Disclosure? Should they even be getting these signed? My feeling is that if the customer signs something, we should scan it. Can the other documents be shredded, or are they required to be kept for a certain period of time?
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#781959 - 07/24/07 08:36 PM Re: Retention of Documents Oviedo Boy
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,485
On the Net
There is no requirement to get it signed and doing so creates work.

You should simply establish procedures for disclosures you are required to give out. You routinely give them out, so you know you have met your disclosure requirements. As was noted above, you keep at least one for retention so you know what was said, and when it was the disclosure that was provided. I did this in my forms book where I sliced and diced all compliance disclosures denoting compliance with the various requirements. Since our Marketing dept handled the printing, they always kept a few copies as well.
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My opinions are not necessarily my employers.
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#781992 - 07/24/07 09:00 PM Re: Retention of Documents Andy_Z
Oviedo Boy Offline
Platinum Poster
Joined: May 2006
Posts: 629
Tennessee
What about the documents we gather in complying with CIP requirements? Are there retention requirements associated with these?
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