We recommend that you retain all information and documentation collected pursuant to Regulation GG for five years after the account is closed or becomes dormant.  While Regulation GG is distinct from any other regulatory framework, and we are not aware of any specific record retention timeframes for Regulation GG, we believe it would be prudent to follow the same record retention timeframe required for customer identification programs and suspicious activity reports, which is five years. 

or resources related to our guidance, please see:

• FDIC, Unlawful Internet Gambling Enforcement Act of 2006 Overview (“These regulations are independent of any other regulatory framework, such as the Bank Secrecy Act or consumer protection regulations.”)

• 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.”)

• FinCEN Regulations, 31 CFR 1020.320(d) (“A bank shall maintain a copy of any SAR filed and the original or business record equivalent of any supporting documentation for a period of five years from the date of filing the SAR.”)