Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
Do you have an updated record retention schedule for ATM envelopes, night drop logs, and fraud dispute paperwork? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Do you have an updated record retention schedule for ATM envelopes, night drop logs, and fraud dispute paperwork?

—

by

The IBA does sell a Guide to Bank Record Retention, but it has not been updated since 2014, and some of the information in the manual may be out-of-date.

The guide recommends retaining ATM deposit envelopes for two years after the date the record is made if there is no deposit slip and the envelope is the only record of the deposit. The guide also recommends retaining night depository logs for six months after an internal audit has been conducted and retaining records related to debit card disputes for two years after the relevant account has been terminated.  

Additionally, we note that Regulation E’s record retention period for retaining evidence of compliance with its requirements (such as investigating claims of fraudulent electronic fund transfers) is two years.

For resources related to our guidance, please see:

  • IBA Guide to Bank Record Retention 2013–14 (Recommendation for “ATM Deposit Envelopes (if there is no deposit slip and this is the only record of deposit): “RD [from date of making] +2y”)
  • IBA Guide to Bank Record Retention 2013–14 (Recommendation for “Night Depository Log”: “AIA [after internal audit] Suggest 6m”)
  • IBA Guide to Bank Record Retention 2013–14 (Recommendation for “Debit Card: Disputes”: “Termination+2y”)
  • Regulation E, 12 CFR 1005.13(b)(1) (“Any person subject to the Act and this part shall retain evidence of compliance with the requirements imposed by the Act and this part for a period of not less than two years from the date disclosures are required to be made or action is required to be taken.”)