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An expertly-staffed hotline, federal regulatory tools, policies and procedures, and unlimited reviews for all sizes of community banks across the U.S. — the only all-inclusive banking compliance advisory. Compliance Hub’s over 1800 products and tools support 48 separate bank compliance areas –an unlimited-access Bank Compliance Library – and conforms to the most recently published federal banking rules and regulations. Whether you are building institutional exam-readiness or a bank compliance program, C/A has all the resources, access, and availability for one membership subscription. Co-owned by the Virginia Bankers Association and 78 other state bankers associations across the country. Contact C/A’s Membership Development Team at (888) 353-3933 or at: info@compliancealliance.com. To learn more about C/A’s new Virtual Compliance Officer service or call (833) 683-0701.

Compliance Alliance Featured Q&A

Question:

What are the record retention requirements for emails between employees and customers? And are we required to keep physical copies of the emails, or can we keep them solely in an electronic format?

Answer:

Email retention isn’t really “one-size-fits-all” – or, said differently, there’s no universal timeline that fits every message in your inbox. Instead, retention tends to depend on the actual content of the specific message.

For example, an email tied to Regulation B (say, related to an adverse action) would likely fall into the purview of § 1002.12, and won’t follow the same retention rules as one discussing BSA (for instance, regarding a CTR), which would be within the scope of 31 CFR 1010.306. Essentially, each topic plays by its own regulatory clock.

As to the paper vs. electronic retention – though this too may generally come down to the content of the email – in most cases, banks are generally permitted to retain records in electronic format, provided the electronic records meet legal standards for accuracy, accessibility, and retention – and, unless a specific law or regulation requires physical (“wet” or “paper”) copies for a particular type of record.

So, what is the smart play? Always start with the content. Ask: “What’s this email really about?” That should typically point you to the right retention schedule and help keep your records in line with both compliance and best practices.

To help with that, we have the following tools that help serve as guides to record retention schedules (broken down by department): Record Retention Schedule Cheat Sheet and Record Retention Policy.

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