The case file and how long it is kept

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1. Why the case file matters

Every Foreign Military Sales case produces paper, and Chapter 6 of Volume 15 of the Financial Management Regulation says what must be kept. It sets guidance on maintaining documents for case files, so that files are uniform and the necessary documents can be found by the activities that need them (FMR Vol. 15, Ch. 6, para. 1.2). The policy applies whether the records are electronic, paper or both.

The regulation gives the file several jobs (FMR Vol. 15, Ch. 6, para. 2.1.5). Its main value lies in keeping a complete and accurate record for audit, and in a standard approach to keeping files. It can also serve as a checklist of planned and completed actions, which helps with execution and closure. A well-kept file makes supervisory reviews easier and makes it more efficient to hand a case from one manager to another.

2. Records rules above the case

Two layers of records policy sit above the case file. Across the federal government, the National Archives and Records Administration (NARA) sets the procedures for disposing of government records, and publishes General Records Schedules (FMR Vol. 15, Ch. 6, para. 1.1.1). Within the Defense Department there are 26 records management programs (FMR Vol. 15, Ch. 6, para. 1.1.2). Each has an appointed records officer, its own manual or instruction, and disposition schedules that must comply with NARA guidelines.

The Department keeps some records longer than NARA requires. Documentation that will be used to support an audit is retained beyond the NARA period (FMR Vol. 15, Ch. 6, para. 1.1.2.1). The Defense Security Cooperation Agency (DSCA) may also issue exceptions to retention periods where case files are needed for another business purpose (FMR Vol. 15, Ch. 6, para. 1.1.2.2). The regulation’s examples are records tied to ongoing litigation and to country suspensions.

The regulation lists the authorities behind this policy (FMR Vol. 15, Ch. 6, para. 1.3). They include the federal records management regulations in title 36 of the Code of Federal Regulations, and the contract file rules at FAR 4.805. They also include NARA’s schedule for financial management and reporting records, which holds the minimum retention requirements for these files, and the Department’s records management instruction.

3. Where files are kept, and by whom

Case files may be kept in a decentralized way by the activities responsible for actions on the case (FMR Vol. 15, Ch. 6, para. 1.1.3). Each activity must keep a comprehensive record of relevant correspondence, worksheets and official forms. Together these form a complete audit trail from the time the case is initiated through closeout or retirement.

When a case is implemented, each implementing Defense Department component decides which supporting activities hold which documents (FMR Vol. 15, Ch. 6, para. 2.1.2). A copy of the Letter of Offer and Acceptance (LOA) may sit with several activities, while copies of the contracts on the case have a narrower distribution. Each component, implementing agency and the Defense Finance and Accounting Service (DFAS) keeps its own portion of the file (FMR Vol. 15, Ch. 6, para. 2.2).

The case manager keeps a directory of where the supporting documentation is held (FMR Vol. 15, Ch. 6, para. 1.1.5). All supporting documentation must be reviewed carefully before disposal or retirement, and checked with the records officer for any litigation hold. The regulation adds a caution that explains why. "A closed case from an FMS purchaser perspective may remain open from a DoD accounting perspective" (FMR Vol. 15, Ch. 6, para. 1.1.5).

4. How the folder is organized

Files are kept in official folders, uniformly titled and filed by section (FMR Vol. 15, Ch. 6, para. 2.1.1). Where more than one folder is needed, they are numbered, and documents in each folder are kept in date order by section. Listings too large to print are not filed in the folder. The cover sheet, or the file itself, records where the electronic listing can be found (FMR Vol. 15, Ch. 6, para. 2.1.3).

Electronic files are encouraged, including the Defense Security Assistance Management System (DSAMS), provided they are complete, secure and readily retrievable (FMR Vol. 15, Ch. 6, para. 1.1.4). Electronic imaging is strongly encouraged where keeping paper originals, such as historical documents and signature pages, is materially expensive but necessary to protect government interests. Components may add documents beyond the required list, preferably as numbered appendices after the required sections (FMR Vol. 15, Ch. 6, para. 2.1.4).

5. The eighteen sections

The minimum documentation for a case is set out in eighteen sections, each with its own table of contents in the regulation (FMR Vol. 15, Ch. 6, para. 3.1). The file opens with a general information cover sheet, the Letter of Request documentation and planning information (FMR Vol. 15, Ch. 6, para. 3.1.1, FMR Vol. 15, Ch. 6, para. 3.1.2 and FMR Vol. 15, Ch. 6, para. 3.1.3). Security assistance survey documents come next, followed by the contractual instruments and the financing arrangements (FMR Vol. 15, Ch. 6, para. 3.1.4, FMR Vol. 15, Ch. 6, para. 3.1.5 and FMR Vol. 15, Ch. 6, para. 3.1.6).

The middle sections follow the case through execution. They hold financial control documents, implementation directives, and updates to DSAMS and the DSCA 1200 system (FMR Vol. 15, Ch. 6, para. 3.1.7, FMR Vol. 15, Ch. 6, para. 3.1.8 and FMR Vol. 15, Ch. 6, para. 3.1.9). Execution records, special logistics and accessorial charges come next (FMR Vol. 15, Ch. 6, para. 3.1.10, FMR Vol. 15, Ch. 6, para. 3.1.11 and FMR Vol. 15, Ch. 6, para. 3.1.12).

The final sections cover government furnished materiel, billing, and the billing side of supply discrepancy reports (FMR Vol. 15, Ch. 6, para. 3.1.13, FMR Vol. 15, Ch. 6, para. 3.1.14 and FMR Vol. 15, Ch. 6, para. 3.1.15). The file ends with review information, closure documentation and records of any reopening (FMR Vol. 15, Ch. 6, para. 3.1.16, FMR Vol. 15, Ch. 6, para. 3.1.17 and FMR Vol. 15, Ch. 6, para. 3.1.18). How a case reaches closure is covered in how a case is reconciled and closed.

6. Retire, never destroy

Documentation accumulates from the start of the case through final closure (FMR Vol. 15, Ch. 6, para. 3.2). After DFAS closes a case, implementing agencies may retire the closed file to document storage, but may not destroy it. DFAS may retire, but not destroy, its own closed case records, including delivery listings. It may do so no earlier than one year after the later of two dates: the latest correspondence with the purchaser about the case, or final closure. Every component, agency and DFAS must keep an accurate record of where retired records are held, so they can be found when needed. The Security Assistance Management Manual sets the retention period for the file at 10 years after the date of case closure (SAMM C6.2.4).

Key terms

Case file	The comprehensive record of correspondence, worksheets and forms that forms a case’s audit trail.
General Records Schedules	NARA’s schedules for managing and disposing of federal records.
Records disposition schedule	A Defense Department program’s schedule, which must comply with NARA guidelines.
Uniform case folder	The eighteen-section structure listing the documents of primary relevance across the Department.
Retire	Move closed case records to document storage while keeping them, which the regulation allows in place of destruction.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Field support on a case produces its own records, from movement logs to site reports. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.