IBA Compliance Connection

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Is there a record retention period for envelopes used to make deposits in the night drop box? Or can we shred them after we log the deposit? We do not log information about deposits on the envelopes themselves and retain a separate log.

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We do not believe that your bank needs to retain the night drop deposit envelopes, given that the envelopes themselves contain no information.

We are unaware of any record retention requirements for night deposit envelopes.  The general recommendation in the IBA’s Record Retention Manual, last revised in 2014, suggests a retention period of six months, noting that this is at the bank’s discretion.  However, if the envelopes themselves contain no information and a log is kept detailing the employees who opened the envelope, the deposit amount, and the date the deposit was received, etc., then a six-month retention period likely is excessive.

The FinCEN rules impose record retention requirements for each statement, ledger card or other record on each deposit or share account, showing each transaction in, or with respect to, that account.  So long as this information is kept with respect to the deposit enclosed in the night deposit envelope, how long to retain the envelope itself is a matter left up to the bank’s discretion.

For resources related to our guidance, please see:

  • IBA Guide to Bank Record Retention 2013-14 “Night Deposit or Drop Envelopes” Recommendation: Bank Discretion – 6 months.”)
  • FinCEN Regulations, 31 CFR 1020.410(c) (“Each bank shall, in addition, retain either the original or a copy or reproduction of each of the following: . . . (2) Each statement, ledger card or other record on each deposit or share account, showing each transaction in, or with respect to, that account; . . . (10)  Records prepared or received by a bank in the ordinary course of business, which would be needed to reconstruct a transaction account and to trace a check in excess of $100 deposited in such account through its domestic processing system or to supply a description of a deposited check in excess of $100. This subparagraph shall be applicable only with respect to demand deposits.”)
  • FinCEN Regulations, 31 CFR 1010.430(d) (“All records that are required to be retained by this chapter shall be retained for a period of five years. Records or reports required to be kept pursuant to an order issued under § 1010.370 of this chapter shall be retained for the period of time specified in such order, not to exceed five years. . . .”)