No, we are not aware of any Illinois laws that specify a record retention period for Call Reports.

While the Illinois Banking Act mandates the Commissioner of Banks to promulgate record retention rules, no such rules have been published. Consequently, we recommend following the FFIEC’s requirement to maintain Call Reports for five years after the report date — in this case, there are no Illinois requirements that would mandate a longer retention period.

For resources related to our guidance, please see:

• Illinois Banking Act, 205 ILCS 5/48.6 (“Unless a federal law requires otherwise, the Commissioner may by rule prescribe periods of time for which banks operating under this Act must retain records and after the expiration of which, the bank may destroy those records.”)

• FFIEC Instructions, Form 031 and Form 041, General Instructions, Retention of Reports (“In general, a bank should maintain in its files a signed and attested record of its completed Call Report, including any amended reports, and the related workpapers and supporting documentation for five years after the report date, unless any applicable state requirements mandate a longer retention period.”)