CLIENT RECORDS
DOCUMENT RETENTION/DESTRUCTION POLICY
Revised July 2009
Mission Statement
Our mission is to comply with all applicable government agencies and provide guidelines and procedures for document retention and destruction that we follow for all clients (both current and former).
Under no circumstances should any records, files or electronic data be destroyed, regardless of the retention periods identified in this policy, if there is a pending regulatory investigation, disciplinary action, legal action, or if the firm has knowledge of the intent by a regulatory agency to launch an inquiry or knowledge of a potential legal claim.
We are in the process of converting from a paper to an electronic document storage system. All paper documents for years prior to 2001 have been placed on our destruction list and are systematically being destroyed.
Current Clients
It is our policy to retain engagement records for a period of seven years from the year end of client or the date of the Firm’s last planning, advice, consultation or representation engagement for such client. Upon the expiration of the seven-year period, we shall destroy our electronic data files. If there is any ambiguity regarding the date for implementation of retention, all doubts shall be resolved in favor of the earliest implementation date. All client information will be retained as electronic files for seven years for current clients. This information will be kept unless you cease to be a client of Fliesher and Dishman, LLP, and after three years from the termination of the relationship, all information will be destroyed without prior notice.
Fliesher and Dishman, LLP retains copies of all prepared tax returns as the electronic return originator (ERO) along with copies of documents used in the preparation. Source documents are returned to clients upon completion of the tax return preparation process. When records are returned to clients, it is their responsibility to retain and protect the original records for possible future use, including potential examination by any government or regulatory agencies.
Any copies of legal documents given to us by the client are retained. Legal documents include, but are not limited to, land/building title, last will and testament, trust documents, etc. These documents are retained for reference and are not originally prepared by Fliesher and Dishman, LLP; therefore, the firm never retains the sole copy of these documents.
Correspondence between the client and the firm is retained along with any correspondence relating to the client.
Former Clients
Fliesher and Dishman, LLP considers a former client to be an individual or entity for which we no longer perform services. This includes clients that have terminated the relationship with us, clients that we terminated the relationship with them, or clients that have not returned for more than one year.
Financial Statements - All former client information is destroyed after three years with one exception. All financial statements including compilations, reviews, and audits are kept for seven years (from period ended) then destroyed. This includes any working papers used to perform this work. Certain items may be prepared during the course of the engagement that is destroyed at the completion. These items include:
Superseded drafts of memoranda, financial statements, or regulatory filings.
Notes on superseded drafts of memoranda, financial statements or regulatory filings that reflect incomplete
or preliminary thinking,
Duplicates of documents.
Copies of client records (unless the clients records contain evidence of audit or other procedures applied by
the Firm).
Review notes.
To do lists (which have been completed), or
Documents that contain typographical errors or other minor errors that result from the normal
business/learning process or from preliminary views based on incomplete information or data.
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