How long is an appropriate time to keep the bi-weekly FinCIN download in paper?

BSA retention is 5 years whether paper or electronic. Which ever you choose, just make sure you maintain proper security over the information.

Given the high security nature of these lists, why keep physical copies at all? You are only required to retain evidence that your searches were completed. From the Info Sharing section of the exam manual:

5. Review the financial institution’s internal controls and determine whether its documentation to evidence compliance with section 314(a) requests is adequate. This documentation could include, for example the following:
Copies of section 314(a) requests.
A log that records the tracking numbers and includes a sign-off column.
Copies of SISS-generated search self-verification documents.
If appropriate, request documentation from FinCEN regarding the bank's history of accessing the SISS.
For positive matches, copies of the form returned to FinCEN (e.g., SISS-generated Subject Response Lists) and the supporting documentation should be retained.

We keep the tracking #'s only with our system results. The actual lists are not retained.

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