RECORDS RETENTION POLICY
EPB Employees Credit Union
- RESPONSIBILITY
Management shall be responsible for the systematic retention of records, set forth herein.
- PERMANENT RECORDS
The following records shall be maintained permanently in fire resistant locked cabinets or the vault in their original form:
Charter, By Laws & Amendments
Certificate of Approval from the NCUA and/or NCUSIF
Current Manuals
Circular Letters and other official instructions and correspondence
Examination Reports (NCUA and State of Tennessee)
Deeds
Abstracts
Title Insurance Policies for Credit Union Building and Other Property
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PERMANENT RECORDS THAT MAY BE MICROFILMED
The following records may be microfilmed after five years, and must be maintained indefinitely
in fire resistant locked cabinets or in the vault:
Copies of each financial and statistical report as of December 31 of each year
Minutes of Membership Meetings
Minutes of Directors and Committees’ meetings
Supervisory Committee Audit Reports and attachments
Supervisory Committee account verification records (unless performed by an outside audit firm)
Monthly Financial Reports disclosed to the Board of Directors
Membership Signature Cards
Credit (Loan) Committee Minutes and Loan Officer Reports
Listing of Records Destroyed
Inventory listing of Office Equipment
Employee Records (while employed)
Authorization for Payroll Deductions (on open accounts)
Authorization to Deduct Insurance Premiums (on open accounts)
Insurance Contracts
Retirement Plan Trust Agreements (for IRA Accounts)
Beneficiary Designation Cards (Payable Upon Death)
Application for Trust Accounts and Trust Agreements (Open and Closed Accounts)
General Ledger Records
Individual Share and Loan Ledgers
Contracts or Agreements
Abandoned Property (Escheat) Reports
Subsidiary Expense Ledgers
Documents Related to Investment of Funds
Bank Reconcilements
Journal and Cash Records
- RECORDS THAT MAY BE DESTROYED AFTER FIVE YEARS
The following records may be destroyed after five years (also may be microfilmed):
Canceled Checks and Voided Checks
Cash Disbursement Vouchers
Bank Deposit Slips and Statements
Records about Life Savings and Loan Protection Insurance Claims & Payments
Registers of Inventory of Money Orders & Travelers Checks
Receipt Forms for Cash Disbursements of Share Withdrawals and Loan Cash Disbursements of Share Withdrawals and Loan Proceeds
Expense Vouchers
Records of Liquidated Credit Unions
Cash Received Vouchers, Tellers’ Proof Sheets and Summaries
- RECORDS THAT MAY BE DESTROYED - VARYING TERMS
Originals of security agreements and financial statements - when the amount of the loan balance is zero or liens satisfied or released.
Loan applications and credit reports - after loan is paid.
Originals of promissory notes and other loan documents - after the loan is re-paid.
Certificates of Debenture and Share Certificates and Notes Payable - five years after being paid.
Real estate mortgages, abstracts, title insurance policies or opinion - after loan is paid.
Pledge of shares of stock and limited guaranty agreements - after loan is paid.
Truth in lending disclosures after loan is paid.
Notice of recession or any other disclosures after loan is paid.
Credit disability insurance forms after loan is paid.
Individual share and loan analysis after examination and supervisory committee audit.
Charge off loan records after recovered or settled.
Records of judiciary action, e.g. judgments, court cases - after recovered or settled.
- TAX IDENTIFICATION NUMBER LISTS
The Compliance Officer will maintain or cause to be maintained a list of all members' tax
identification numbers. Such a list may be maintained by utilizing the Credit Union's data
processing system or by some other retrievable manner that is deemed appropriate by the
Compliance Officer and Credit Union Management. Every effort will be made to collect
correct tax identification numbers (TINs) for all members. This is an area of compliance
that affects many aspects of the Credit Union operation and one that requires close attention
in order to maintain as accurate a listing as possible.
- RECORD KEEPING AND ACCESS PROCEDURES
The Credit Union Compliance Officer is responsible for developing a system for
maintaining the following records for a minimum of five years:
- Extensions of credit in excess of $10,000.
- Each remittance or transfer of funds, currency or other monetary instruments, checks,
investment securities, or credit of $10,000 or more outside of the United States.
- Each advice, request, or instruction received or given regarding any transaction resulting
in the transfer of currency or other monetary instruments, funds, checks, investment securities,
or credit of more than $10,000 to or from any person, account, or place outside of the United
States, even if later canceled or if such transaction is incomplete.
- Signature authority documents.
- Statements of ledgers showing account activity.
- All checks or share drafts drawn on the Credit Union.
- Drafts or money orders drawn on the Credit Union or issued and payable by it.
- All debits in excess of $100 except service charges or periodic changes based on
previous agreements with the member.
- Each check or draft of $10,000 or more drawn on or issued by a foreign bank (bank
operating outside of the United States), which the Credit Union has paid or presented
to a non bank drawee for payment.
- Each item of $10,000 or more received directly by letter, cable, or other means (not
through a domestic financial institution from outside the U.S.).
- Each receipt of currency, other monetary instruments, checks, or investment
securities, and each transfer of funds or credit of $10,000 or more received on any one
occasion directly and not through a domestic financial institution, from a bank, broker,
or dealer of foreign exchange outside the United States.
- Records of accounts where an employee of this Credit Union has signing authority
for the institution involving a foreign account.
- All records needed to reconstruct a share draft account for checks and drafts in
excess of $100 deposited. Deposit slips utilized by the Credit Union or the Credit Union's
data processing system will differentiate between "cash and other deposits."
- The name, address, and TIN of the purchaser of each certificate of deposit, a
description of the instrument, method of payment used by the member, date of transaction
and information on any person presenting a certificate for payment, a description of the
instrument presented, and the date of the transaction.
- Each extension of credit over $10,000 (except mortgage loans) with the name and
address of the borrower, and the amount and purpose of the loan.
- SPECIFICS
- Bank Secrecy Act.
- Name and address of borrower, amount of loan, date of loan, nature and purpose of loan - 5 years after loan closing.
- Chronological logs and Currency Transaction Reports - 5 years from creation of document
- All share and deposit account records - 5 years from creation of record.
- Electronic Funds Transfer Act.
All electronic transfer related disclosures and records - 2 years.
- Equal Credit Opportunity Act and Regulation B.
- Credit applications and information used to evaluate applications - 25 months after
applicant is notified of decision on the application.
- Written notification of action taken on application - 2 months after applicant is notified
of decision on application.
- Written statement of specific reasons for adverse action on application - 25 months
after applicant is notified of decision on application.
- Any written statement given to Credit Union by an applicant alleging discrimination
prohibited by ECOA or Regulation B - 25 months after applicant is notified of decision
on application.
- Any compliance monitoring information gathered pursuant to ECOA or Regulation
B - 25 months after applicant is notified of decision on application.
- Copy of written notification of adverse action and list of specific reasons for adverse
action taken on an existing account - 25 months after borrower is notified of adverse
action taken on account.
- Expedited Funds Availability Act.
All Regulation CC related disclosures and records - 2 years.
- Fair Credit Reporting Act.
Notice of use of credit report - 2 years after applicant/borrower
receives notice of use of credit report.
- Home Mortgage Disclosure Act.
- Loan Data Register - 3 years after filing with NCUA
- FFIEC Disclosure Statement - 5 years after receipt from FFIEC
- NCUA Regulations.
- All loan related documents - 2 years after loan closing
- Loan related real estate appraisals - 25 months after notice of action taken on loan.
- Real Estate Settlement Procedures Act and Regulation X.
- Escrow account related documents - 5 years after the last escrow service on the loan
- HUD 1 Form, HUD 1A Forms and related documents - 5 years after settlement
- Good Faith Estimate - 2 years after delivery to applicant/borrower
- Truth-In-Savings.
All account disclosures - 2 years after disclosures are provided to member
- Truth-In-Lending and Regulation Z.
Regulation Z disclosures (including periodic statement) - 2 years after disclosures provided to applicant/borrower
Approved: 05/18/2005
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