Crazy question-
We are required to retain account statements permanantly. However, we have an individual requesting statements from 1990 and I don't know if we actually have to provide them or not. It would take a lot for us to pull the statements/recreate them.

Does anyone know if the retention requirement translates into us having to retain the record in the off-chance that the account holder requests it- even if it was over 20 years ago? Or are we just retaining the record for legal purposes (meaning 7 years for most things)?

I checked the retention schedule from our state (NM) Financial Institutions Division and I don't even see anything remotely related to the actual customer statements (unless you count them as general correspondence...2 years). I know several major banks let you go back a few years online/offline, but I don't think I've seen anything over 5-7 years.

I'd be interested in a knowledgeable answer.

Also, other than the signature cards (which we have to keep for 6 years from account closing) and CIP form (5 years as per BSA), does anyone retain any of the following PAPER-BASED information for any length of time (not imaged [yet]:

(Daily)List of new deposit accounts added today

Maintenance report that correlates to added accounts that is used by verification clerk to ensure it was input correctly.

Manual entry forms and verification of phone/fax/email intra-account transfers (for customers)

Service charge refund authorizations

Authorization for direct payment

Account updates (DL#, Address change, etc.)

Authorization from customer to close account

Daily list of unrecoverable overdrafts


We seem to keep these things idefinitely in the basement and I want to start putting some time frame around the retention. 5 or 7 years from creation should be enough, no? I'm hoping when we get a new imaging system we can image everything tied to the account.

I double-checked the NM retention schedule and found the following entry for checking accounts:

Ledgers (statements) - 5 years from preparation
Ledgers (statements) and checks [UNDELIVERED] - 5 years from preparation

I take this to mean that we would have to provide either the originals or a re-created copy of their statements (including the checks listed thereon) for a period of 5 years from the date originally created.

I'm not aware of any federal regulations.