BSA Record Retention: The Five-Year Box
Every bank keeps a room nobody visits until an examiner asks for something. What the Bank Secrecy Act rules say belongs in it, and for how long.
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Somewhere behind the teller line there is a storage room. Banker's boxes, labeled by year. A scanner humming in the corner. Nobody thinks about it on an ordinary Tuesday.
Then a request letter arrives, and that room becomes the most important place in the building.
How long the paper stays
The retention rule in the Bank Secrecy Act regulations is short. § 1010.430 says all records required by the chapter shall be retained for a period of five years.
Five years is longer than most staff remember a customer. It is shorter than many people guess. Boxes from six years back are not covered by this clause, though another rule or a bank's own policy may still keep them.
Both sides of the check
People picture a check as its face. The payee, the amount, the signature. The rule asks for more than that. § 1010.430 requires a retained copy of both the front and back of each check, draft, or similar instrument.
The back is where the endorsements live. Whoever deposited it, and where, shows up there. A scan of the front alone leaves out half the trail.
Records the bank already makes
Here is a quiet relief for the operations team. § 1010.430 says records required by the chapter may be those made in the ordinary course of business by a financial institution.
So the statement, the deposit ticket and the wire log can do the job. Nobody has to copy them into a second set of files. A money transmitter leans on its own logs the same way when a SAR clock starts.
There is a catch for the gaps. § 1010.430 says a financial institution must prepare a written record if no record is made in the ordinary course of business. If the system never captured it, someone writes it down.
Large loans get their own line
Lending staff sometimes assume recordkeeping belongs to the deposit side. It does not. § 1010.410 requires financial institutions to keep a record of each extension of credit over $10,000, except credit secured by real property.
A mortgage falls outside that clause. A large equipment loan does not.
Findable, not just kept
A record buried in an unlabeled box has been kept and cannot be used. The rule speaks to that too. § 1010.430 says records must be filed or stored so they are accessible within a reasonable period of time.
That is the real test of the storage room. When the letter arrives, can someone walk in, pull the right year, and find the back of one particular check before the week is out?