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Old 05-31-2007, 03:25 PM
AngryAuditor AngryAuditor is offline
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Default Record Retention Policy in a payment card processor

Can anyone give me any examples or point me to any regulations that pertain to how long a processor must retain inactive accounts and the associated transactions?

Along the sames lines, are processors subject to the banking regulations when they are not an issuer?

Thanks!
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Old 07-29-2007, 07:54 AM
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jbhall56 jbhall56 is offline
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Originally Posted by AngryAuditor View Post
Can anyone give me any examples or point me to any regulations that pertain to how long a processor must retain inactive accounts and the associated transactions?
If you are in the US, your organization will be driven by your state's banking laws related to retail or revolving credit record retention as well as the requirements of your regulatory oversight body such as the Office of Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Office of Thrift Supervision (OTS) or the National Credit Union Administration (NCUA).

That said, typically the transaction records have to be retained anywhere from three to five years during the life of the retail or revolving credit agreement and then after the termination of that agreement.

To confirm this, get in touch with your state and federal bank or financial institution examination groups.

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Originally Posted by AngryAuditor View Post
Along the sames lines, are processors subject to the banking regulations when they are not an issuer?
Yes as they are covered under the federal lending regulations and therefore come under the oversight of at least the OCC. However most are examined by the FDIC as they are typically owned by an FDIC insured institution.
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Jeff Hall, Director, Risk Advisory Services
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www.mcgladrey.com

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Old 08-02-2007, 01:00 PM
mike07 mike07 is offline
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Default merchant processor

Hey Jball thanks for the input. I was seeking the same information pertaining my merchant account. I had a few problems with credit card numbers saying inactive but it must have been the software.
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Old 08-02-2007, 05:54 PM
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jbhall56 jbhall56 is offline
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I should have added that while retention is typically three to five years, in the state of Iowa, retention for state banking laws is 11 years. Go figure.
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Jeff Hall, Director, Risk Advisory Services
RSM McGladrey Inc
801 Nicollet Mall, 11th Floor, West Tower
Minneapolis, MN 55402-2526
612 376 9280 - office
612 395 7280 - facsimile
www.mcgladrey.com

The views presented are those of the writer and are not necessarily those of RSM McGladrey Inc
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