OCC Reminds Banks to Fulfill Recordkeeping Obligations

The Office of the Comptroller of the Currency ("OCC") reminded national banks and federal savings associations of their responsibilities concerning (i) the maintenance of records, (ii) records retention and (iii) examiner access.

Specifically, the OCC reaffirmed the authority to (i) require prompt and complete access to all relevant books, records or "documents of any type" from national banks and federal savings associations, and (ii) communicate "freely" with employees, officers or directors of banks. The OCC also emphasized that the permanent deletion of internal communications – including correspondence over chat and messaging platforms that tout the "ability to 'guarantee' the deletion of transmitted messages" – conflicts with the OCC's expectations for sound governance, compliance, risk management and safety principles.