Documenting Truth in Savings Compliance Answer by Jim Bedsole and John Burnett, BOL Gurus Guru Bios
Question: A depository institution is required to retain evidence of compliance for a minimum of two years after the date when disclosures must be made or action is required under Regulation DD. What exactly does this mean? Do we keep copies of the Truth in Savings Disclosures provided to the clients? Do we need to have new Truth in Savings Disclosure signed when an account changes to another account type?
Answer by Jim Bedsole: You don't need to keep every TIS disclosure you provide and you don't need to have customers sign the TIS disclosure for account changes. You do need to be able to reproduce the TIS disclosures for each account type you offer or have offered in the past two years. You also need to be able to demonstrate your operating procedures for new accounts personnel adequately address providing TIS disclosures. You also need to demonstrate your training efforts for those same personnel on how to properly comply with TIS. You can also have documentation for internal reviews of TIS compliance and what the findings were and what was done to correct any deficiencies. That all constitutes the required evidence of compliance.
Answer by John Burnett: You will also have to retain copies of your deposit advertisements for the two year period, as well as deposit ads posted to your bank's Web site.
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