Certification Deadline at a Utility Cooperative

Sequence matters because certification is a governance claim, not a storage claim. First, obtain a board resolution and charter establishing an executive records committee with the CEO, general counsel, CFO, CIO, and CRO, with decision rights over schedules, holds, and shared-drive remediation. This converts 'IT's job' into assigned accountability and gives the CRO authority to enforce decisions across 14 units. Second, refresh the records policy and create a records-coordinator network: each business unit names a coordinator who drafts and owns schedule content, while the CRO supplies methodology, legal review, and approval. Third, conduct a risk-ranked inventory focused on merger due diligence, antitrust, safety, financial, and customer records, not all 4.2 TB. The nine-month roadmap should have measurable milestones: policy reissued, schedules adopted for the six uncovered units, legal-hold procedure implemented, shared-drive cleanup prioritized, and an internal audit test. Two staff cannot personally certify 14 units; they can certify a functioning system of accountability, schedules, and controls.

Business units should own the content of their schedules because they know the records and the business process; the CRO should own the method, legal alignment, approval workflow, and quality control. IT should not own retention decisions, because storage is not appraisal. To handle refusals, the CRO should avoid treating schedule adoption as a voluntary administrative task. Use the executive committee to set a deadline, publish a RACI, and escalate nonparticipation to the audit committee or CEO with risk statements: missing schedules mean inconsistent disposition, hold failures, and merger diligence exposure. Start with the highest-risk units and use a pilot schedule to demonstrate value rather than waiting for consensus. Tie completion to merger integration conditions and department-level performance measures. Provide templates and one-hour working sessions so refusal is not caused by workload. Document escalations. If a unit still refuses, the CRO should not simply write a schedule without validation; instead, issue an interim schedule approved by counsel and flag the unit as a compliance exception.

Before closing, the two organizations remain separate legal entities, so records sharing must be controlled. The CRO should work with counsel to establish a clean-team protocol for competitively sensitive information, especially customer, pricing, and antitrust-relevant records. Due diligence should use an index or data room rather than transferring full repositories. The CRO should prepare a records inventory and retention map for the deal team, identify active legal holds at both organizations, and prohibit disposition of any records potentially relevant to the transaction or antitrust review. After signing but before close, integration planning can define the target retention schedule, system inventory, and records of the transaction. Do not commingle records or grant broad access to the acquirer's staff. At close, apply a documented records-integration plan with hold reconciliation, schedule mapping, and disposition freezes. The CRO should also retain deal records under the appropriate schedule and document all information-sharing decisions.