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#1704263 - 05/30/12 11:51 AM DOEP Supporting Documentation
amlzed Offline
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Joined: May 2012
Posts: 46
Good morning,

We are in the process of transitioning from discrete e-filing for our SARS and the use of a separate system for batch filing of CTRs and DOEPS, into a wholly integrated platform; more or less.

My question regarding DOEPs is regarding record retention. I realize that the record retention is five years. Does that mean we have to maintain the paper copies of files and supporting documentation utilized for the annual review/approval process from the date of initial designation?

Example: We exempt a qualified business in 2000 and every year in January we revisit for our own internal approval process to maintain the exempt status. Every year we have kept the supporting documentation utilized to justify the exempt status and we just keep adding more and more paper.

Once we go to the "integrated" platform we will have the ability to utilize PDFs to attach supporting documentation.

So my question is -- do we need to hold on to all of that old paper data OR scan it all into the system or can we just pick up our internal renewal process in January and start adding our docs there?

Thanks!
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#1704265 - 05/30/12 12:08 PM Re: DOEP Supporting Documentation amlzed
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
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The BSA record retention requirements do not require you to keep anything on paper. Microfilm, microfiche, electronic, imaging are all acceptable as long as you can find the records in a reasonable period of time.

That's pretty forward thinking for a regulation penned in 1986.
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#1704944 - 05/31/12 11:08 AM Re: DOEP Supporting Documentation amlzed
amlzed Offline
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Joined: May 2012
Posts: 46
Thanks Ken. But do you, or your institution, as a practice keep all of the supporting documentation from the initial exemption to five years after you revoke them? Thanks for your help!
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