Hello! Recently I was reached out to by our bookkeeping department with a question regarding the recordkeeping requirements for Debit Card Applications for those that have been closed. Currently we are keeping these for a year. So all of 2020 will be kept until the beginning of 2022.

My question is, do we need to keep a copy of these? If so how long do we need them for? Also, if there is a recordkeeping requirement, could someone point me towards the regulation?

Thank you all for your time!

What do you mean "closed"?

I believe by "closed" they mean deactivated, either by means of account closure or when a card is replaced.

Well, if you received an application for a debit card, you want to maintain a copy of the application to prove that the card was not issued as an unsolicited device (1005.5). Record retention for Regulation E compliance is usually two years (1005.13). Whether you need to retain these on closed cards for that period of time is a business decision.

In that there is no requirement for an "application for a debit card" the bank has effectively created this requirement. And if it "reflects evidence of compliance" with Reg E because you have disclosures in there or anything indicating Reg E was followed as required, I'd agree with Randy that 1005.13 applies. This demonstrates compliance with 1005.5(a) so you need it for "a period of not less than two years from the date disclosures are required to be made or action is required to be taken."