For how long should we retain signature cards? I have a version of the IBA Record Retention Manual that recommends five years. What if we replace signature cards on current accounts with new signature cards; for how long should we retain the old signature cards?

The statute of limitations for written contracts in Illinois is ten years. 735 ILCS 5/13-206. Consequently, we recommend retaining signature cards (which typically are part of the account agreement) for ten years after the termination of the account. We even recommend that signature cards on active accounts for which the cards are no longer in effect be retained for the ten-year period after they are replaced with new signature cards.

The Record Retention Guide refers to the BSA/AML regulations, which require financial institutions to retain certain documents for five years. 31 CFR 1010.410. However, as you pointed out, we advise following the longer ten-year period generally addressed by the Illinois law.