Overall, our recommendation is to pick a date on which your bank will begin scanning new loan files into your electronic storage system, rather than attempting to convert all of your existing open loan files at once.

We polled our internal IBA Compliance Division Advisory Committee on best practices for electronic document conversion of open loan files. More than one member advised against trying to convert all open loan files into electronic format. The consensus was that it can be difficult to play catch up when trying to scan all open files. Rather, our committee members suggested picking a date going forward from which all new loan files and all new items on existing loan files will be scanned into your system.

Some methods suggested for implementing the file conversion include establishing a centralized scanning department at the bank, or adopting a rule that the first person to handle a document is responsible for scanning it. We also have inquired whether any of our committee members can share a checklist, procedures, or other form used when converting paper files into an electronic format and will add any documents received to our forms library on GoToIBA.com.

Additionally, the OCC has published guidance on adopting electronic record retention systems, identifying areas of concern that should be considered when developing an electronic record retention policy, and noting that an electronic record system must have “sufficient accuracy, accessibility, and integrity to achieve and accomplish all essential functions and purposes that pertain to the specific records that are contained within that particular system,” among other recommendations.

For resources related to our guidance, please see:

• OCC Advisory Letter,  AL 2004-9, (“Despite the absence of specificity in the [E-SIGN] Act’s standards, an electronic record system of a national bank must have sufficient accuracy, accessibility, and integrity to achieve and accomplish all essential functions and purposes that pertain to the specific records that are contained within that particular system. Likewise, the system must have the accuracy, accessibility, integrity, and other attributes needed to comply with regulatory requirements applicable to those specific records. Until more specific standards are developed, banks should design, implement, and operate their electronic records systems so that they are adequate to serve the following purposes and functions according to the nature of the retained records:
  • Potential use in litigation support,
  • Internal and external audits and controls,
  • Bank supervision, and
  • Compliance with regulatory requirements.”)