We are developing a database to email our online banking customers that their monthly statement is available for viewing. How long should we retain the proof of delivery in the database? We keep the actual statements available for viewing indefinitely. But I couldn't find any record retention requirements for proof of delivery. Help?

Does "proof of delivery" mean a list of those consenting e-banking customers to whom a notice of statement availability was sent? If so, then Regs E and DD both require "evidence of compliance" with the rules regarding periodic disclosures. In both cases, your "evidence" must be maintained for specified periods of time. In a paper-based environment, you are also required to provide "evidence of compliance" that statements went into the U.S. mail. In both cases your evidence will be procedural and the retention periods will be the same.

Yes, it's just the email that their statement can be viewed. They still get their paper statement, as we have not gotten to the point of offering to eliminate their paper statement. But I wanted to make sure that we are keeping evidence of the email notification for when we do get to that point. We're doing this in phases. Looks like 2 years for Reg E and DD. Thanks for your help.

If you're producing and posting e-statements across the board and also mailing paper statements, the price for both is the same. How are you going to motivate customers to opt into e-only statements and give up the paper?