Purging account and member records

The Bank Secrecy Act (BSA), 31 CFR 103.100, implements the information sharing provision of Section 314(a) of Title III, of the USA Patriot Act. The provisions require institutions to search their deposit and loan records to determine whether they maintain or have maintained:

• records for an individual, entity, or organization named in the request during the preceding 12 months
• transactions not linked to an account conducted by a named subject during the preceding six months (for example, wire transfer)

As a result, Portico retains zero-balance share, share draft, certificate, and loan accounts until the purge date is 365 days or greater than the last transaction date for the account. Once you meet the 365-day requirement, Portico removes the account on the next purge date.

Generally, purges occur on the third Friday following each quarter-end; however, some exceptions may apply. For credit unions with Y in the Deferred Compensation field on the Credit Union Profile - Credit Union tab, Portico only purges members and accounts in the first purge after year-end.

The following reports support purge activities.

• Purged Collection Accounts Report 735
  Lists all account-related information as of the date Portico purges the share or loan from Collections.
• Purge by Loan Type Report 930
  Lets you enter and update the list of loan types that your credit union does not want to purge during the quarterly member purge program.
• Purge Exception Report 935
  Lists members and member information that Portico purged, as well as members with zero balances that did not purge.