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How long should we retain guardianship documents that we requested from customers to open checking and savings accounts after the accounts have been closed? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

How long should we retain guardianship documents that we requested from customers to open checking and savings accounts after the accounts have been closed?

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We recommend retaining the guardianship documents for five years after the accounts have been closed or become dormant.

FinCEN’s Bank Secrecy Act rules require banks to retain any identifying information required by their Customer Identification Program (CIP) for five years after the account is closed or becomes dormant. If the guardianship documents were not required by your CIP, but you relied on them for customer identification purposes, we think it would be prudent to adhere to the five-year rule for them, as well.

For resources related to our guidance, please see:

  • FinCEN Regulations,31 CFR 1020.220(a)(3)(ii) (“The bank must retain the information in paragraph (a)(3)(i)(A) of this section for five years after the date the account is closed or, in the case of credit card accounts, five years after the account is closed or becomes dormant. The bank must retain the information in paragraphs (a)(3)(i)(B), (C), and (D) of this section for five years after the record is made.”)