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Corporate Records Retention Schedule

Function List

Introduction

The Corporate Records Retention Schedule is arranged in a two-level hierarchical structure or taxonomy. The first level is the "Function". Functions serve as broad categories which

assist in navigation of the retention schedule. Within each Function, "Record Types" are defined with a more detailed description. For the purposes of the retention schedule, Functions

are not meant to mirror organizational structure. Instead, they are intended survive organization changes and still maintain their validity, thereby eliminating the need for updates to the

schedule each time an organizational change occurs. Retention periods are assigned to each Record Type based on legal requirements and/or business need. All Records of the

Company, regardless of format, media, or mode of transmission, should be classified according to the Corporate Records Retention Schedule at the earliest point in the life cycle of the

record (preferably at creation).



Function Description

Accounting/Finance The systematic recording, reporting, and analysis of financial transactions. Includes all records that feed directly into the Financial Statements of the

Corporation, its affiliates or subsidiaries. Does not include records related to specific customer/client banking transactions or the filing of tax returns for the

corporation.

Administration Organizing and overseeing business operations from a management, coordination and/or oversight perspective. Includes records related to administrative

functions of both the holding company and affiliates/subsidiaries, as well as, records related Investor Relations.

Audit/Risk Independent review and examination of company systems and processes to assess accuracy, security, reliability, effectiveness and risk; and to ensure that

records and information retained by the company comply with company policies, laws and regulatory requirements. Includes records related to both internal

and external risk assessments, investigations, examinations, and audits.

Branch Banking Administration and operation of retail "brick and mortar" branch banking locations where customers can transact business face-to-face with bank employees

for most products and services offered by the bank and it's affiliate companies. Generally includes only records kept in the branch or forwarded to branch

operational support units for final disposition. Also includes records specifically related to Private Services which are created and maintained in branch

offices. Note that most records originated in branch offices will be filed under record types included in other functional categories such as Transaction

Processing, Investments, Trust.

Compliance Policies, processes and methodologies designed to facilitate compliance with Federal, State, and Local laws and regulatory requirements. Includes records

related to compliance policy generation, training and monitoring.

Corporate Records Records related to the actions of Boards of Directors, stock transactions, stockholder meetings, regulatory filings, and corporate transactions such as

acquisition or sale of corporate entities (e.g. Board of Directors Meeting Minutes).

Corporate Security Protection of the company's personnel, property and assets. Includes physical security and fraud investigation, but does not include security of electronically

stored information (see Information Technology).

Correspondent Banking Providing payment processing or other financial services to another financial institution.

Credit/Lending Providing credit products & services to individuals or businesses. Includes all records related to extending credit regardless of loan type (e.g. Mortgages,

bankcards, overdraft protection).

Deposit Accounts Records related to standard deposit products & services offered by the bank and not covered by other related functions. Does not include Private Services,

Transaction Processing, Treasury Management or Trust

Facilities Functions related to the maintenance, repair, safety, energy utilization, construction, and financing/leasing of any company office or facilities.

Human Resources The administration of all functions related to the management of Human Resources including recruitment, hiring, disciplinary action, performance

assessment, compensation, benefits, safety and training.

Information Technology The design, development, installation, security, implementation and maintenance of information systems and applications, both hardware and software.

Includes Business Continuity.

Corporate Records Retention Schedule

Function List

Insurance Coverage by contract binding a party to indemnify the company against specified loss in return for premiums paid. Includes all records related to insuring the

corporation's assets against loss due to the negligence of employees or service providers, accident, or natural disaster. Except for Workers' Compensation

Insurance Policies and Claim matters, this does not include employee benefits, which is under Human Resources.



International All products and services related to business conducted outside of the USA.

Investments Administration and operations related to the offering of non-banking investment products to clients. Includes records related to Broker/Dealer services,

Wealth Management services and general investment advice; but does not include Trust services.

Legal The management of all legal claims, suits or actions filed against or on behalf of the corporation, its affiliates or subsidiaries or to which the corporation, its

affiliates or subsidiaries are or could be a party. Records under this category should include but are not limited to legal opinions, records related to legal

administrative matters.

Marketing Actions/communications intended to promote or encourage the purchase or use of company offered products and services. Includes the community service

initiatives of the company.

Procurement Administration and operations related to the acquisition of goods and services for the corporation which are provided by third parties. Includes purchasing,

contract/service agreement negotiation and management, and vendor relationship management (e.g. Corporate Travel Records)

Tax All accounting records specifically related to the filing of Federal and State Tax Returns for the corporation, its affiliates, or subsidiaries

Transaction Processing All functions related to the high volume processing of payments transactions in check, draft or electronic format. Includes functions such as Proof, Check

Processing, Exceptions/Returns, Image Exchange, ACH and Wires.

Treasury Management Activities related to Treasury Management services including check clearing strategy and support for products and services intended to assist business

banking clients in efficiently managing cash and related activities. Includes customer contracts and records related to account reconciliation & analysis,

positive pay, controlled disbursement, remote electronic deposit services.

Trust Services offered to both individuals and business clients where the Corporation, its affiliates or subsidiaries act as trustee or fiduciary agent regarding trust

funds or estates through custodial arrangements, stock transfers or related services. Includes records related to both Corporate Trust and Personal Trust

products.

1

Records Retention Schedule 2

3

4

Functional Area Record Code Record Type Description Retention Retention Start Event

(New) Period 5

(Years)

Original invoices paid or 'To be paid'. Examples: Expense

payments, vendor invoices, facilities bills, insurance premium

Accounting / Finance ACC-100 Accounts Payable payables, insurance company payables, account payable 6 After Fiscal Year-end 6

register, payables reports, AP posting, sale invoices, credit

memos, expense



All records related to payments received or expected to be

Accounting / Finance ACC-110 Accounts Receivable 6 After Fiscal Year-end 7

received. Examples: Cash receipts, invoices, AR posting.



Records related to monthly expense allocations to affiliate /

subsidiary cost centers from centralized support or shared

Accounting / Finance ACC-120 Allocations service cost centers. Includes: Facilities expenses to 3 After Fiscal Year-end 8

affiliates/subsidiary cost center, shared facilities expenses

where applicabl

Records generated from or produced for the Asset Liability

Asset Liability Committee. Examples: Minutes, agendas, memos, reports to

Accounting / Finance ACC-130 6 After Fiscal Year-end 9

Committee the committee, analysis reports, Zions ALCOM, ALCO

meeting materials.

Supporting material for budgets and forecasts.

Accounting / Finance ACC-140 Budget Files Examples: Prior year budgets, financial planning, worksheets, ACT+1 After Fiscal Year-end 10

work papers, appropriation file.

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Combined RRS Mapping

New to Old



Lower Case = New Record Type

Lower Case = Bank 1 Old Record Type

UPPER CASE = Bank 2 Old Record Type



No. Function Record Code Record Type Record Type Description Retention Retention Previous Previous

(New) (Old) Period Start Event Record Retention

(Years) Code Period



Original invoices paid or 'To be paid'. Examples: Expense

payments, vendor invoices, facilities bills, insurance premium

Accounting / After Fiscal

1 ACC-100 Accounts Payable payables, insurance company payables, account payable 6

Finance Year-end

register, payables reports, AP posting, sale invoices, credit

memos, expense

Accounts payable register Bank 1 5 years

Bills paid and invoices Bank 1 7 years

Expense reimbursements to employees Bank 1 3 years

ACCOUNTS PAYABLE ORIGINAL INVOICES PAID OR TO BE PAID FIN004 6

INVOICES FROM INSURANCE COMPANIES FOR PREMIUMS

COMPANY PAYABLE INVOICES INS008 120

DUE.

RECORD OF UNPAID ITEMS TO INSURANCE COMPANIES. IT

COMPANY PAYABLES REPORT IS A SYSTEM GENERATED REPORT MTD THAT CANNOT BE INS009 120

REPRODUCED.

CREDIT MEMOS / SALES INVOICES CREDIT MEMOS / SALES INVOICES FIN028 120

INVOICES RECEIVED BY FACILITIES AND FORMAL PAYMENT

FACILITIES EXPENSE PAYMENTS REQUEST PREPARED/SUBMITTED FOR PAYMENT MAINTAIN FAC016 120

BRANCH FILE COPY

Accounting / All records related to payments received or expected to be After Fiscal

2 ACC-110 Accounts Receivable 6

Finance received. Examples: Cash receipts, invoices, AR posting. Year-end



DETAIL TRANSACTION LIST OF ALL UNPAID/UNREFUNDED

INVOICES SORTED BY CLIENT ETC. THIS DETAIL IS USED TO

M/E ACCOUNTS RECEIVABLE INS020 120

SUPPORT THE A/R GL MONTHLY AND CANNOT BE

REPRODUCED AFTER THE M/E DATE.

Records related to monthly expense allocations to affiliate /

subsidiary cost centers from centralized support or shared

Accounting / After Fiscal

3 ACC-120 Allocations service cost centers. Includes: Facilities expenses to 3

Finance Year-end

affiliates/subsidiary cost center, shared facilities expenses

where applicabl

EXPENSE ALLOCATION FILE ELECTRONIC FILE OF EXPENSE ALLOCATION FOR ALL UNITS FAC015 120

(R-N)

VARIOUS MONTHLY ALLOCATIONS OF CENTRALIZED

ALLOCATIONS FIN007 120

SUPPORT OR SHARED SERVICE COST CENTER EXPENSE

Records generated from or produced for the Asset Liability

Accounting / Asset Liability Committee. Examples: Minutes, agendas, memos, reports to After Fiscal

4 ACC-130 6

Finance Committee the committee, analysis reports, Zions ALCOM, ALCO meeting Year-end

materials.

Asset/liability management records Bank 1 3 years

ALCOM REPORTS WEEKLY ASSET/LIABILITY COMMITTEE AGENDA REPORT ADM001 84

ANALYSIS REPORTS, ZIONS ALCO, MINUTES, REPORTS TO

ASSET LIABILITY COMMITTEE FIN010 9999

COMMITTEE, AGENDAS, AND MEMOS.

Supporting material for budgets and forecasts.

Accounting / After Fiscal

5 ACC-140 Budget Files Examples: Prior year budgets, financial planning, worksheets, ACT+1

Finance Year-end

work papers, appropriation file.

Budget reports Bank 1 2 years

SUPPORTING MATERIAL FOR BUDGETS AND FORECASTS,

BUDGET FILES FIN017 24

PRIOR YEARS' BUDGETS

FINANCIALS AND BUDGET SPREADSHEETS OF FINANCIALS AND BUDGET INFORMATION OPS071 36


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