Office of the Superintendent of Financial Institutions
This memorandum sets out areas that are to be considered by companies
in preparing a program of retention/destruction of records. Companies
are expected to prepare these programs and to have them for review
by OSFI on request.
Enquiries may be addressed to:
Telephone: (613) 990-7609
Material pertaining to the years of operation examined at the
time of any examination by this Office should not be destroyed before
the completion of the subsequent examination.
Consideration should be given to provincial statutes on retention
and limitation. These specify periods of legal liability. It would
be prudent to add a margin of safety to the legal retention/limitation
Claims records should be maintained for review by the Office.
Sufficient records should be kept indefinitely to ensure that claims
are not paid twice. In some provinces, the statute of limitations
may be extended, giving minors the right to bring an action against
an insurer after the minor has reached the age of majority. Therefore,
it is necessary to keep all such claim files past the prescribed
The company should establish the legal status of microfilmed records
as substitutes for original records, according to the evidence laws
of Canada and the provinces.
General ledgers and journals should be maintained for review by
the Office for two complete examination cycles.
Minutes of directors' and shareholders' meetings, registers of
directors, shareholder records, correspondence of historical value,
etc. should be retained indefinitely in their original form.
Specimen copies of all policy forms should be retained indefinitely.
Items of an internal nature, such as statistical runs, may be
destroyed without microfilming.
Companies should retain indefinitely the records pertaining to
Documents relating to the insured's dealing with the policy (change
of beneficiary, dividend election, etc.) should be retained on the
policy file. Policy files in respect of paid-up policies and matured
but unpaid endowments should be retained indefinitely.
Reinsurance and management treaties and contracts should be retained
indefinitely unless authorization has been given by the Office for
Companies should ensure that their program of retention/destruction
of records also meets the requirements of Revenue Canada and any
other authorities for whom records must be maintained.