Question of the Week

Question: How long do we keep chat logs with our members?

Answer: For the same length of time as you would keep a written record of the same retention category. 

That is, if the chat log is involved with information collection on the opening of a new account for example, you would keep the record for a period of time associated with the Bank Secrecy Act (five years from the time the account closes).

If the record is associated with information gathered on a loan application, you would keep the chat log for 25 months, which is the period for certain information to be kept under Reg B.

If there is no mandated period for that record, you would keep it for a reasonable time period, say two years or whatever generally accepted accounting principles designate. This would cover most online chats that are not covered by law or regulation, or that might be clerical in nature regarding a member’s account. 

The only caveat to having this discretion over non-specific records would be for Texas state-chartered credit unions, whose rules under 7 TAC 91.405(d) require that documents without a record retention period stated in an applicable state or federal rule be kept for a period of five years. To quote: “Subject to applicable law, any other type of document not specifically delineated in this rule may be destroyed after five years or upon expiration of an applicable statute of limitations, whichever is longer.”

If you need further information on specific kinds of records, Cornerstone does have a model record retention policy offered through our partners at CU PolicyPro. That can be found in the 10000 section of the model policies here: https://www.leagueinfosight.com/cu-policypro-client-listing.