We recommend that you retain all corporate resolutions, including outdated resolutions, for at least five years after termination of the business account.

FinCEN’s Bank Secrecy Act regulations require you to retain each document granting signature authority over a deposit or share account for five years after they are created. The IBA’s Guide to Bank Record Retention recommends retaining resolutions for five years after the account is terminated and recommends retaining canceled corporate resolutions for the same period.

For resources related to our guidance, please see:

• FinCEN Regulations, 31 CFR 1020.410(c)(1) (“Each bank shall, in addition, retain either the original or a copy or reproduction of each of the following: . . . Each document granting signature authority over each deposit or share account, including any notations, if such are normally made, of specific identifying information verifying the identity of the signer (such as a driver’s license number or credit card number.”)

• 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.”)

• IBA Guide to Bank Record Retention 2013-14 (“Resolutions (see also: Signature Records)” Recommendation: “Termination+5y”)

• IBA Guide to Bank Record Retention 2013-14 (“Canceled Corporate/Organization Resolutions (Legal Order/Contract)” Recommendation: “Termination+5y”)