IBA Compliance Connection

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What are the required retention periods for drawer counts and cash in and cash out tickets?

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In some cases, these records will be subject to FinCEN’s five year record retention requirement for certain deposit account records. For example, the five year retention requirement applies to “each statement, ledger card or other record on each deposit or share account, showing each transaction in, or with respect to, that account” and to records “which would be needed to reconstruct a transaction account and to trace a check in excess of $100 deposited in such account.” If your bank maintains other records of account transactions or that would be needed to trace checks of over $100, we do not believe that the five year retention requirement would apply. But if your cash blotters and cash tickets are the only records of such transactions, they should be retained for at least five years.

If the five year record retention period does not apply, the record retention period for these documents is a business decision for your bank. The IBA’s Record Retention Manual recommends retaining teller blotters for two years after an audit and retaining cash in and cash out tickets for one month after an audit (assuming that the tickets fall outside of the five year retention requirements). However, those retention periods are merely suggestions and are not required.

For resources related to our guidance, please see:

  • 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. . . .”)