Financial institutions are obligated to assemble records requested through administrative summons/subpoena or judicial subpoena even during the pendency of customer challenge proceedings. See 12 U.S.C. § 3411. Financial institutions have the right to resist a government request for records on various grounds (i.e., vagueness, undue burden); such rights remain unaffected by the Act but cannot be asserted by the customer.
Updated December 18, 2015