Answer:
Under Reg E, an application for an access device may be oral or written. Clearly, you cannot retain oral applications. In order to document that cards have been requested most issuers use some form of written record. It may be on an account signature card or it may be a separate document. Section 205.13 of the regulation requires that you retain documentation of compliance with the regulation's requirements for two years from the time the record is required to be made. From that you can infer that you should keep any written record of a card request (whether it's an actual written, signed application or a record that an oral application was received) for two years. There's also a provision in that section that calls for you to retain the record longer if you've been notified of certain types of investigations or proceedings.
First published on BankersOnline.com 1/19/09
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