There are no specific record retention requirements as to retaining records related to 314(a) requests. However, the FFIEC BSA/AML Examination Manual states that “documentation that all required searches were performed is essential.” It recommends printing off “search self-verification document for each 314(a) subject list transmission” and a “Subject Response List.” It also notes a financial institution’s duty to protect the security and confidentiality of this information, and this duty is specifically required by the BSA regulations (31 CFR 1010.520(b)(3)(iv)(C)).

Most record retention manuals recommend savings such records for five years, citing the BSA regulations. However, note that the five year number was basically pulled out of thin air. Two years might be adequate. It’s in the bank’s judgment.