If we have active account types for which we no longer offer those accounts, must we maintain a copy of a TIS disclosure in order to provide the account holder in the rare event they asked for one? I should add that we are converting to a new account system so I'm not sure they are going to set up disclosures for any old account types.

Thanks in advance.

Reg DD's record retention requirements state that we must retain account opening disclosures for each account "offered" to consumers. Although we are not opening new accounts for these types, those customers for which we are allowing to keep the current fee/interest rate structure are still accounts we are offering to those that are grandfathered in.

Consider the implications of an examiner or auditor performing a UDAAP review of your bank. I am going to want to compare the fees that we are charging and the parameters of your system to what was disclosed. If your response is, "I don't know what we disclosed since that was an old system" you could have some serious UDAAP risk. I'd recommend creating .pdf files of disclosures for all active account types and saving them where they could be retrieved if needed.