We have some certificate of deposits that were obtained during a merger. Basically, the information for the CDs were brought over, but we do not have copies of the disclosures provided at account opening. These certificates have renewed and we have retained copies of the renewal notices.

For retention purposes (Section 1030.9), do we need to just keep the renewal notices for 2 years from when the disclosures were required or do we need to retain both the original documentation provided to the depositor at account opening plus all subsequent renewal notices? I'm just trying to figure out if we have an issue since we don't have the original account opening documentation. Your help is greatly appreciated.

A depository institution shall retain evidence of compliance with this part for a minimum of two years after the date disclosures are required to be made or action is required to be taken.

If the accounts are over 2 years old, technically there is no requirement to retain the original disclosures.

Thanks!!!