For electronic retention to work, you need to tell the application when to
start calculating the retention period.  Even with a flat number of years
as the retention period, should the system start that clock from when the
document is created, when it is finalized, when it is moved to a
repository (if you operate that way), or after some other triggering event
(e.g., delivery to customer, closure/expiration of contract, termination
of employee)?  

I understand the frustration with how vague an ACT retention trigger can
be, but it's still better than one that's undefined (which can result in
misunderstandings or downright errors).

Just one woman's opinion.

Pilar C. McAdam, CRM, ERMm
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Los Angeles, CA

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