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#26877 - 08/06/02 02:08 PM Old E-Banking Disclosure Retention?
Compliance Buzz Offline
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Joined: Feb 2002
Posts: 319
NJ
Has anyone heard of a rule requiring that we post or maintain old e-disclosures (for Online banking, ATM, Debit Card, etc.) for a period of 6-months after a change? I was asked this question by our E-banking department and have never heard of this before. Any help or guiding me in the right direction would be appreciated.
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#26878 - 08/06/02 02:38 PM Re: Old E-Banking Disclosure Retention?
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Well, depending on the type of disclosure that you are talking about, the retention period to prove compliance may be longer. For example, the retention period for any disclosure delivered under Regulation E is two-years. Therefor, you would have to keep copies for any electronic Regulation E disclosures for at least two years.

However, I don't believe that you have to make them available for viewing by your customers.
Last edited by rlcarey; 08/06/02 02:40 PM.
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#26879 - 08/07/02 11:33 AM Re: Old E-Banking Disclosure Retention?
Richard Insley Offline
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Richard Insley
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Toano, VA
Unless state law speaks directly to the e-environment, you simply follow the retention requirements of each applicable law, rule or regulation. Your first step is to determine whether web content is your official disclosure (many banks continue to provide the official copies on paper and courtesy copies on the website). If not, then you would simply consider the need to retain old content in order to resolve consumer complaints. RESPA and BSA have 5 year standards and almost everything else is 24 or 25 months.
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#26880 - 08/07/02 01:58 PM Re: Old E-Banking Disclosure Retention?
Andy_Z Offline
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Perhaps they were thinking of the customers statements being available vs. disclosures?

Even the interim regulations required disclosures to be available for only 90 days.
Last edited by Andy Z; 08/07/02 02:05 PM.
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