We refer to them as destruction holds and they are initiated whenever there is a known or reasonably anticipated legal action, regulatory or governmental investigation, or audit. Within our database we do distinguish the reason for the hold, but that's simply for internal tracking purposes.

Mary Frances Janicik, CRM
  ----- Original Message ----- 
  From: Barrett Walker<mailto:[log in to unmask]> 
  To: [log in to unmask]<mailto:[log in to unmask]> 
  Sent: Tuesday, December 22, 2009 5:18 PM
  Subject: [RM] Regulatory Holds = Legal Holds?


  I'm familiar with legal holds associated with pending or reasonably anticipated 
  litigation.  My questions are one of syntax more than anything:  

  Would the same process apply for pending or reasonably assumed 
  investigations by regulatory agencies?  
  Would this be called and treated as a Legal Hold, or should it be defined as 
  a "Regulatory Hold" or some other distinction from Legal?  
  Should policy address "regulatory holds" as part of the Legal Hold process or 
  as a separate policy?

  Thanks gor being there.

  Long time lurker, first time poster!

  Warmest Regards!

  Bear

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