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We do Fedline Advantage for wires that go out of and come in to the bank. For how long do we have to retain documentation of the wires? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We do Fedline Advantage for wires that go out of and come in to the bank. For how long do we have to retain documentation of the wires?

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We recommend that you retain documentation of Fedline transfers for five years. The BSA regulations require you to retain documentation of any funds transmittals of $3,000 or more for five years. 31 CFR 1010.410(f)31 CFR 1010.340(d). As to transmittals of less than $3,000, the record retention period is up to you. (The FFIEC’s former Fedline Booklet recommended retaining the FedLine PC printer log for five years, but that has since been made obsolete.) If you need further guidance, the Fedline Advantage customer support department recommended contacting your account executive.

Also, Regulation E requires that you retain documentation of compliance with its notice and disclosure requirements on electronic fund transfers for two years. 12 CFR 1005.13(b). (Note that Regulation E does not apply to Fedwire or similar, institution-to-institution/business-to-business wire transfers. 12 CFR 1005.3(c)(3).)