Meeting/Event Information
Records Management for Regulated Financial Entities/Institutions (Banks)
Recap: Records Management for Regulated Financial Institutions
Thank you to everyone who joined us for our recent virtual meeting with Mike DeVanna. The recording of the meeting can be found on our YouTube channel.
This session, presented by Michael DeVanna, focused on records management for regulated financial institutions. Key themes included regulatory frameworks, program design, data governance, and the integration of records management into broader information governance.
Key Topics Covered
The discussion addressed two tiers of regulation:
- Regulations governing the structure of a records management program
- Regulations dictating specific retention periods
- Regulatory Agencies
- FDIC
Program Requirements
The following program requirements will assist the company in developing its program.
- Media-neutral retention schedules
- Complete and accurate records
- Clear roles and responsibilities
- Mandatory training and board oversight
- Proper disposition of records
Retention Period Examples
Mike spoke about the retention periods in the various regulations that cover the records. Due diligence is required to make sure the retention you choose is the right one for your company. Always consult your legal and risk people to gain an understanding of the requirement.
- NACHA: 7 years
- OFAC: 10 years
- Patriot Act: 5 years (varies by record type)
Privacy & Security Integration
- Regulation P: governs personal financial data
- Emphasis on anonymization and pseudonymization
- FTC rules for non-depository institutions (e.g., 2-year retention limit)
Implementation Strategies
- Treat information as a corporate asset
- Overcome organizational inertia
- Break down silos across departments
- Tailor communication to different audiences
Integration with Information Governance
Records management is positioned as a core component of information governance, alongside privacy, security, data governance, and risk management.
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Over the course of a records manger’s career, s/he may work in a multitude of industries developing and implementing records management programs. Healthcare, oil & gas, utilities, academia, or nonprofit: each industry presents unique challenges, as well as recordkeeping commonalities. The world of finance, it may be argued, is the most highly regulated industry for records management, as it intersects with privacy, security, and other facets of information governance. This presentation will discuss the regulatory environment and the challenges of implementing a records management program in the world of finance.
Michael DeVanna, MLS, CRM, IGP is the AVP - Records Retention Officer at EverBank, a national bank headquartered in Jacksonville, Florida. He holds a master’s degree in library science from Simmons University; has been a Certified Records Manager since 2008; and has been certified as an Information Governance Professional since 2020. Prior to taking on his current role at EverBank, Michael developed records management programs at: Florida Blue (Jacksonville), Aramco Americas (Houston), Saudi Aramco (Saudi Arabia), Blue Cross Blue Shield of Massachusetts (Boston), and Old Dominion Electric Cooperative (Glen Allen, VA). Michael, an ARMA member since 2001, coauthored publications for ARMA International, including: Developing Electronic File Structures (2013), Retention Management for Records and Information (2015), and Records & Information Management Core Competencies, 2nd ed. (2017).
