Question: How long must the bank maintain electronic disclosures?
Answer:
Prior to October 1, 2008, all banks in the United States were required to maintain their electronic disclosures on their home banking websites for at least 90 days. However, industry practice generally sees banks retaining this information for much longer than the required timeframe. In turn, the Federal Reserve Board has eliminated the 90 day requirement. In a similar decision, the Federal Reserve Board also eliminated the 90 day requirement concerning electronic delivery and redelivery of disclosures through the use of e-mail.
These electronic communication and disclosure requirements were withdrawn from Regulations B (the Equal Credit Opportunity Act), DD (Truth in Savings), E (the Electronic Funds Transfers Act) M, (Consumer Leasing) and Z (Truth in Lending). These regulations have been altered to simply require institutions to provide the consumer disclosures in electronic form, subject to the federal Electronic Signatures in the Global and National Commerce Act.
It is important for banks to provide their employees with up-to-date and ongoing training on banking regulations to ensure compliance with all federal laws.
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