by Coppelia Padgett, Senior Analyst, AffirmX
It can be a daunting challenge just keeping up with how long to keep various records, many of which have multiple regulations that impact how long them must be kept.
To assist those charged with managing records at their financial institution, we have compiled a Record Retention Schedule for banks.
The guideline is a universal listing of types of records banks may create or use followed by a general guideline on how long those records should be kept. We use the word “guideline” on purpose, because there are relatively few records that have Federal retention requirements written into the code or statue. For example, Regulation B, the Equal Opportunity Credit Act (ECOA), requires that adverse action notices must be kept for 25 months exactly. That is the law.
In contrast, the Fair Housing Act requires financial institutions to place the fair housing logo on all their mortgage related advertising. But the FHA does not require financial institutions to keep copies of the advertising for a certain number of months.
In fact, the FHA doesn’t require financial institutions to keep copies of advertising at all. Of course, to determine whether you are complying with the FHA, examiners may ask for your advertising during their examinations and will likely not be amused if you don’t have it available for them. Thus, the guidance that has developed is to hold advertising for one examination cycle and then discard, but it is not written in the statue. It is a guideline.
We hope these guidelines can provide some direction about how long to keep items. Where there are legal retention requirements, it has been noted.
Request a Copy
For a complimentary copy of AffirmX’s 13-page record retention guidelines for banks, please contact AffirmX’s Mike Lane.