I'm stuck! I know that just about everything BSA-related has a retention period of 5 years. However, when it comes down to brass tacks, I'm having a tough time finding the citation for 5 yr retention of DDA records to reconstruct deposit items over $100.00.

Here's Section 103.34 of the BSA regulation (My particular item is found at 103.34(b)(10)). BSA Reg. Notice that it doesn't say anything anywhere in the Section about the retention duration.

I've looked elsewhere, and have found the 5 year retention stated in other sections, but it seems to only apply to the section it appears in.

What am I missing? Thanks for any help you can provide!

Be patient with me. This link takes you to the BSA regulations. Before you proceed, please note that they are divided into nine subparts, A - I. Now, click on 103.38 and find the language: (d) All records that are required to be retained by this part shall be retained for a period of five years.

When the regulation refers to " this part" it is referring to all the subparts in combination; i.e. the entire regulation. Any record you are required to keep under BSA is subject to this paragraph. The CIP regulations make some specific distinctions from that overall standard.

The BSA regulations show the effects of being cobbled together over a period of decades. At one time there was a smattering of different record retention requirements, but this section was added to homogenize them.

Ken, you are awesome! Thanks so much - that is just what I needed!