The Complete Compliance and Ethics Manual 2023

Audit

AUD100

Corporate policies and procedures, manuals, and related materials.

Examples include:

• Policies and procedures manuals

Indefinitely

Retain indefinitely. (Because a firm retention period cannot be determined in advance, the status of these records must be periodically reviewed. The records must be destroyed when they are no longer needed for operational, tax, audit, or legal purposes.)

Audit

AUD120

Records from external financial audits of company and business units not covered elsewhere.

Examples include:

• Audit Committee notes or minutes,

• Audit workpapers (e.g., external financial audits),

• Audit correspondence (e.g., external audit oversight),

• Preliminary and final audit reports (e.g., external financial audits),

• Management responses (e.g., external financial audits), and

• Supporting documentation (e.g., external auditor oversight).

7 years

Retention period begins when the record is created.

Audit

AUD130

Records related to audits and investigations by governmental agencies. Includes governmental agency orders, hearing notices, audit reports, and correspondence. Does not include litigation or tax audits and appeals.

See LEG150 for litigation

See TAX130 for tax audits and appeals

Examples include:

• Governmental agency audits, reports, inspection reports, notices of Violation, warnings, citations, or hearing notices;

• Governmental agency correspondence; and

• Governmental agency orders.

Act+ 3 years

Active for the life of the investigation. The retention period begins when the investigation has concluded.

Tax

TAX100

Federal, state income and franchise tax returns

Records that represent actual tax returns and related workpapers for federal, state, and local income and franchise taxes.

Examples include:

• Federal/state income tax returns and

• Income and franchise tax workpapers.

Indefinitely

Retain indefinitely.

Tax

TAX120

Federal and state property tax and miscellaneous tax returns

Records that represent actual tax returns, related workpapers, audits and appeals for property taxes, and federal and state miscellaneous taxes that are not classified separately elsewhere.

Examples include:

• Property tax, sales and use tax, or other miscellaneous or federal or state tax returns;

• Estate and gift, occupancy, real property, excise, or stock transfer taxes; and

• Tax workpapers.

Indefinitely

Retention period begins when the record is created.

Tax

TAX130

Tax audits and appeals

Audits, audit workpapers, and appeals related to audits and appeals.

Examples include:

• Tax appeals,

• Tax audit reports, and

• Tax workpapers.

15 years

Retention period begins when the record is created.