Record Retention Schedule For Credit Unions - AffirmX

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Record RetentionSchedule for CreditUnionsJanuary 15, 2015

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015This Record Retention Schedule created by AdvisX was designed to provide a summary of recordretention requirements of various regulations. Where specific requirements are not specified in aregulation, guidance is given based on best practices. We welcome any input users have for refining thischart. If you find any errors or have other suggestions, we invite you to share those with us for futureupdates to this schedule.Note: This guide has been prepared for informational purposes only and is not legal advice. You maywish to consult legal counsel for record retention requirements for your financial institution's specificcircumstances, particularly for retention requirements governed by the laws of your state.ADMINISTRATIVE RECORDSCharterArticles of IncorporationBylaws and amendmentsCertificate of Share InsuranceCertificates or licenses to operate various governmentprograms (i.e. HUD, Savings Bonds, IRA) Minutes of meetings, including annual shareholdersmeetings, board of directors, credit committee, andsupervisory committee and including approval of loans toofficers and directors Minutes of Special Membership meetings Supervisory committee annual audit Supervisory committee records of member accountverification Applications for membership and joint share accountagreements Designation of Beneficiary Card Abandoned property: escheat reports (until payment tostate) Records preservation program and list of recordsdestroyed One copy of each financial report NCUA Form 5300 (or itsequivalent), Credit Union Profile Report, NCUA Form 4501(or its equivalent) and other annual reports as submitted toNCUA or your state's credit union department at the end ofeach quarter NCUA examination reports Paid bond claimsRecords of Robberies, Burglaries, Non-Employee LarceniesCommitted or AttemptedRETENTION PERIOD Share and loan balances for each member’s account;A financial report listing all of the institution assets andliabilities;Bank reconcilements;Listing of the credit union’s financial institutions, insurancepolicies, and investments.Audit Reports and Record of account verificationGeneral LedgerAsset and Liability AccountsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949Permanent retentionPermanent retention with on- andoff-site duplicates or back-upsPAGE 2

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015ADMINISTRATIVE RECORDSRETENTION PERIOD Journal and cash record and EDP daily proof listingDormant Accounts listingATM audit tape or Network tapePersonnel Affirmative action plans (EEOC)Off premises record preservation logProof tapes of Share and Loan RegistersSecondary Capital Account Disclosure and AcknowlEdgementSubsidiary Expense LedgerALM Management RecordsFinancial Transaction Register Court orders7 years Powers of Attorney15 years after expiration Bonds and Endorsements3 years following expiration 1099 listing, summary3 years Security program and logUntil superseded Inventory of furniture and equipment and depreciationschedule2 years after disposal of furnitureand equipment or fullydepreciated Bond (premium receipts and declaration page)Current and last year’s Insurance policies2 years after expiration ofcoverage Insurance coverage reportCurrent and last year’s Personnel records6 years after termination Application and resumes approved3 years Application and resumes declined6 years Personnel attendance records3 years Safe deposit box access tickets2 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 3

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015ADMINISTRATIVE RECORDSRETENTION PERIOD Canceled signature cards for safety deposit boxes2 years after close Copies of rent (safety deposit box) receipts2 years Leases or contracts, vendor closed accounts2 years after close General Correspondence4 Forced entry records6 years Records and/or contents of drilled safety deposit boxes6 years Building contracts7 years Deeds to credit union propertyPermanent Payment correspondence from NCU or othergovernmental agenciesThrough next examination period Government manuals (current version)Permanent Register of all instances when financial information about amember is disclosed to the Federal government either withmember authorization or in response to a court orderPermanent Bank statements for credit union’s accountsPeriodic destruction: 5 yearsfollowing close of fiscal year, 1year after the date the record iscreated Dividend/interest refund payment records4 years Dividend register4 years Expense register and expense ledger5 years following close of fiscalyear Invoices/bills/statements5 years following close of fiscalyear Expense vouchers/invoices5 years after close of fiscal year Budget2 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 4

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015ADMINISTRATIVE RECORDSRETENTION PERIOD Debit card settlement report3 years Cash difference records6 years Checks7 years Voided checks4 years Money orders5 years Voided money orders4 years Traveler’s checks (including voids and stop payments)6 years Stop payments on CU checks2 years (recommended) Employee benefit plans (including supportingdocumentation)6 years following filing date Employee Eligibility Form I-93 years following date of hire or 1year following separation,whichever is later. Employee Information Report EEO-1Undetermined Employee Withholding Certificate Form W-44 years following tax year Injury reports5 years following settlement ofinjury, unless hazardous materialswere involved, then 30 years. Pension plan documents (IRA, etc.)6 years following last transaction Records of additions to or deductions from wages paid3 years Wage rate table2 years Social Security tax records6 years following the tax year Ads for employment2 years Military leave documentation5 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 5

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015ADMINISTRATIVE RECORDSRETENTION PERIOD All personnel records related to discrimination claims3 years or until final disposition ERISA annual reports and summaries6 years Criminal Referral Form (CR Form 2362)10 years Declaration of Forgery3 years, but 6 is recommended IRS correspondence4 years following tax due date Coverdell ESA Contribution Information Form 5498-ESA4 years following tax year Depreciation schedules4 years following tax filing Designation Agreement to File 10984 years Dividend Reporting Form 1099-INT4 years following tax year Employee Withholding Certificate Form W-44 years following tax year Employer’s Annual Federal Unemployment Tax ReturnForm 9404 years following tax year Unemployment tax records4 years following tax year Employer’s Quarterly Federal Tax Return Form 9414 years following tax year Miscellaneous Income Form 1099-MISC4 years following tax year Reconciliation of Income Withheld from Wages Form W-34 years following tax year Sales and use tax records4 years following tax year Tax bills/statements4 years following tax year Taxpayer Identification and Certification Form W-94 years following tax year Wage and Tax Statement Form W-24 years following tax yearCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 6

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015COMPLIANCE REGULATIONSRETENTION PERIODEvidence of Reg. B compliance Applications, supporting information and requirednotifications (adverse action notices & ECOA notice) Pre-screened solicitations (text & criteria) Written complaints alleging violations of ECOA Self-tests information related to Fair Lending, if any Right to Appraisal Notice and/or waiver of that right Written complaints Credit reports/financial statementsEvidence of Reg. E compliance EFT error resolution documents (logs, spreadsheets,memos etc.) Error-related documentation (notice of error from sender,support documentation, investigation) 25 months(12 months for business creditover 1 million gross revenues)2 years from date of notice of errorndWire Remittance Pre-payment Disclosure, receipt (2 )disclosure, or combined disclosure*Change in terms noticesNew service disclosureATM reportsAYM settlement statementsATM transaction recordsEvidence of Reg. Z compliance Applications, support materials TILA disclosures (initial & closing) New Loan Estimate Form* (Effective 8/1/2015) New Closing Disclosure* (Effective 8/1/2015) Right of Rescission forms Evidence of compliance with requirements regardingperiodic statements Copies of advertisements (including transcripts of non-printmedia) and Copies of marketing materials used by the institution Billing Error Notice Billing Error Dispute Documentation Ability to Repay (documentation of efforts to determineincome, assets and other ATR factors2 years2 years3 yearsMortgage Servicing Rules* (note that the small servicersexemption may apply) Mortgage Servicing FileSchedule of transactions, instruments, communication withborrower notes, data fields relating to loan, documentsprovided to borrower regarding error resolution or lossmitigationCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.19491 year after loandischarged/transferredPAGE 7

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015COMPLIANCE REGULATIONS Prompt Payment, Crediting, & StatementsWritten requests and evidence of complianceRETENTION PERIODNot specified; guidance 1 examcycle Force-placed insurance (disclosure letters)Not specified; guidance keep copyof disclosure in file for life of loan Error resolution & info requests (evidence ofcompliance)Not specified, but mustacknowledge requests within 5business days and have aresponse in 30 (this implies a logis necessary) Early intervention with delinquent borrowerso Disclosureso Logo Trainingo Evidence of complianceNot specified; guidance keepcopies in loan file of all notices.Small servicer exemption. Continuity of contact with delinquent borrowersNot specified; guidance keepcopies in loan file of all notices.Small servicer exemption Loss mitigation procedureso Evidence of complianceo Trackingo Loss mitigation applicationsNot specified; guidance keepcopies in loan file of all notices,logs, tracking materials for 1 yearafter loan discharged. Smallservicer exemption.*Items to be implemented by the CFPB under the Dodd-Franklegislation.Evidence of Reg. CC complianceNo specific record retention requirements for holds placed, butinstitution must be able to prove compliance with funds availability,notices, and other aspects with its procedures.NCUA Part 707 Compliance with Truth in Savings Act Although a copy of each disclosure does not have to beretained; institution must show established procedures forpaying interest/dividends. Rate and balance informationmust be sufficient to verify interest/dividends paid onaccounts. Sample disclosures needed.Evidence of Reg. C compliance (HMDA) Complete register (LAR) & Modified HMDA-LAR for public Public disclosure statementCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.19492 years2 years3 years5 yearsPAGE 8

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015COMPLIANCE REGULATIONSRegulation V: Evidence of Fair Credit Reporting Actcompliance Pre-approved/pre-screened credit offers (criteria,requirements for collateral, text)Evidence of Reg. X (RESPA) compliance HUD-1 (Good Faith Estimate) HUD-1A (Settlement form) New Loan Estimate Form* (Effective August 2015) New Closing Disclosure* (Effective August 2015) Good Faith Estimate of Closing Cost Applications, support information Documents related to kickbacks & unearned feesretention Affiliated Business Arrangement documents Servicing Disclosure Statement Record Keeping for Escrow AccountsRETENTION PERIOD3 years5 years (longer for items underinvestigation or dispute)BSA Currency Transaction ReportsCTR exemption recordsLarge currency transaction formsCorrespondence for law enforcement or other agencyMember Identification Program (CIP)Certificates Purchased or PresentedChecks in Excess of 100Designation of Exempt Person FormExtensions of credit in excess of 0,000 (not securedby real estate)International Transportation Report (Form 105)Logs and RegistersPurchase of monetary instruments of 3,000 or morein currencyTaxpayer Identification NumbersCorrespondence to or from law enforcement or otheragenciesOFAC records of complianceCash received vouchersCertified checks/receiptsJournal vouchersCopies of wire advicesWire transfer (debit/credit) and Wire Transfer logWire transfer documentsFinCen(314(a) Information RequestsATM deposit envelopesCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.19495 years5 years for cash, otherwise 90daysPAGE 9

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015COMPLIANCE REGULATIONS Suspicious Activity Report & supporting documentationNational Flood Insurance Act Flood Hazard Determination forms Evidence of flood insurance if required Notices of force-placed flood Insurance*Regulation D: Reserve Requirements for DepositoryInstitutionsRETENTION PERIOD5 years from date of report (or upto 10 years for items underinvestigation)Life of the loanOne examination cycleDaily Reserve CalculationRegulation G & H: SAFE Mortgage Licensing ActFI must submit and keep current(within 30 days) changes ininformation on Mortgage LoanOriginators on the NMLS Registry,but no in-house recordrequirements are made.Regulation M: Consumer LeasingAdvertising and alternative disclosures (merchandise tags) relativeto consumer leasingRegulation P: Privacy of Consumer Financial InformationElectronic Signatures in Global & National Commerce (E-SIGNAct)E-SIGN Act requires financial institutions to seek consumerconsent to the use of electronic records. Although individual formsdo not need to be kept, institutions must show that procedures arein place to ensure consent and to ensure retainable forms areprovided to consumers.Servicemembers Civil Relief Act (SCRA)Loan documentation & work papers for any credit that has beendesignated under the SCRA for protection.COPYRIGHT 2015 ADVISX www.advisx.com 888.980.19492 yearsNo specific recordkeepingrequirements. But evidence ofprocedures recommended for oneexam cycle.No specific recordkeepingrequirements. But evidence ofprocedures recommended for oneexam cycle.Life of the loanPAGE 10

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015COMPLIANCE REGULATIONSRETENTION PERIODHomeowners Protection Act (HOPA) PMI disclosures Annual notice of right to cancel PMILife of the loanFair Housing ActAll advertising and marketing is required to have the equal housingdisclosure or Fair Housing logotype.There is no requirement on howlong advertising and marketingmust be maintained. Butrecommended to keep for oneexam cycle.HOEPA Rule (mortgage rules) (effective January 2014)Must have list available for allfederal-related mortgageapplicantsWritten list of housing counseling agencies that meets thesummary of data instructions for Housing Counseling Agency listLoan Originator Rule (mortgage rules) (effective January2014) Records of all compensation paid loan originatorsLoan Originator compensation agreements or contractsUnlawful Internet Gambling Enforcement Act (Reg. GG) Documentation of accountholders engaged in illegalgamblingReg. GG risk assessmentUIGEA Risk Analysis Form3 years after the date of eachsuch receipt or payment 6 years after investigationends or judgment(recommended)6 years (recommended)6 years (recommended)MEMBER RECORDSRETENTION PERIODIndividual deposit/share and loan ledgers7 yearsPeriodic statements (data)7 yearsPayroll deduction authorization5 years after expirationCourt orders& releases of members’ accounts5 yearsMembership lists (data)Until supersededWithdrawals5 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 11

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015MEMBER RECORDSRETENTION PERIODDeposits5 yearsJournal1 yearTrial balances, automated or non-automateda. If statement or account history retainedOptionalb. If no alternate record5 yearsForm 1099a. 1099 listing, summary5 years3 yearsIRA account records10 years after closeChecks paid (any format)7 yearsStop payment orders1 year after expirationUndelivered statements5 yearsDaily Overdraft ReportTrhough 1 audit cycleCopies of advices of deposits1 yearStatement – (any format)7 yearsNew and closed account Reports6 yearsZero balance report1 monthChange of Address records1 yearDormant accountPermanentReturn item record5 yearsShare Certificates5 years following maturitySignature Guarantees3 yearsBad check records1 yearACH returns and adjustments6 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 12

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015MEMBER RECORDSRETENTION PERIODACH affidavit for unauthorized or revoked activities1 year from date of returnACH audit documentation6 yearsACH debit authorizations2 years after cancellingauthorizationACH transaction reports6 yearsPayroll deduction/DD authorizations2 years after cancellationDebit card exception report6 monthsLife savings insurance claims (paid)6 yearsNight drop log5 yearsSubpoenasUntil case is completely concludedLOAN RECORDSRETENTION PERIODLoan applications approved or denied25 months or until loan is paid,whichever is greaterLoan application denial notice25 months from date of membernotificationDisclosure statements2 years after date disclosures arerequired to be madeSecurity agreementUntil loan is paid or collateral isreleasedFinancing (UCC-1) statement or verification of vehicle lienUntil loan is paid or collateral isreleasedReal estate mortgageUntil loan is paid, then releaseCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 13

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015LOAN RECORDSRETENTION PERIODNotice of rescission2 years or until loan is paid,whichever occurs firstAbstracts, deeds, title opinions, title insurance, insurance policies,etc.Until loan is paidSecurity agreement for property held by the credit unionUntil loan is repaid and propertyreturnedReceipt for Return of Property7 years from date of return ofpropertyCollateral held by the credit union (stock, C.D.'s, insurancepolicies, jewelry, guns, etc.)Until loan is paid or until released.Return to borrower and obtainreceipt.Insurance loss payable noticesUntil superseded or until collateralis releasedBorrower's and co-maker's credit reports and financial statementsUntil loan is paidCredit disability insurance formsUntil loan is paidOpen End Agreement to PayPermanentCanceled open end agreements7 years after canceledCredit committee minutesPermanentCharged off loans and records10 yearsFlood insurance certificatesLife of loanHazard insurance policiesLife of loanCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 14

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015LOAN RECORDSRETENTION PERIODCredit card stop list1 year1098 data5 yearsPromissory notes6 years after loan is paidBankruptcy records10 yearsJudgments (satisfied and unsatisfied)7 yearsCollection files7 yearsDelinquent loan reports3 yearsDelinquent loan statistics2 yearsLoan reports (paid loans, overdrawn accounts)6 yearsBorrower insurance claims6 years following paymentCredit disability insurance report4 yearsCreditor’s paid disability insurance claims6 yearsLoan protection insurance reports4 yearsLoans drawn over limit report2 audit cyclesLoan notes4 yearsFederal student loans—audit reports5 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 15

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015LOAN RECORDSRETENTION PERIODFederal student loan records and documents5 yearsCREDIT UNION INVESTMENTSRETENTION PERIODDocuments evidencing investment of funds3 years after closeSafekeeping records and receipts5 years after closeBroker confirmations2 yearsBroker invoices2 yearsBroker statements3 yearsDescriptive literature on securities disposed of2 yearsBuy and sell agreement: mortgage backed securities2 years after maturity or saleIT RECORDSRETENTION PERIODComputer printouts and reportsThrough the completion of theaudit cycleProgram documentation, operators instructions, change logs,modifications, test data, and results1 year following the life of theprogramTape retention: Daily Month-end Year-end1 month1 year7 yearsACH processed register6 yearsCOPYRIGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 16

RECORD RETENTION SCHEDULE FOR CREDIT UNIONSAS OF 1/15/2015Schedule is based on information from: NCUA National Credit Union Administration (www.ncua.gov/legal/pages/default.aspxFFIEC Federal Financial Institutions Examination Council (www.ffiec.gov/cra)CFPB Consumer Financial Protection Bureau; Regulations (www.consumerfinance.gov/regulations/)For more information on AdvisX and its cost-effective,technology-driven compliance, risk, and IT services for financialinstitutions, visit us at www.advisx.com, call us toll-free at1.888.980.1949, or email us at info@advisx.com.Other recommended products and inviteyoutovisithttp://riskinbox.com.Alow- ‐cost,subscription- IGHT 2015 ADVISX www.advisx.com 888.980.1949PAGE 17

This Record Retention Schedule created by AdvisX was designed to provide a summary of record retention requirements of various regulations. Where specific requirements are not specified in a . Sample disclosures needed. 2 years Evidence of Reg. C compliance (HMDA) Complete register (LAR) & Modified HMDA-LAR for public