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Record Retention for ATM/Debit Card Apps

Question: 
I cannot find the record of retention for ATM/Debit Card applications or alterations in the state of MI. How long must they be kept?
Answer: 

Answer from Randy: 1005.13 Administrative enforcement; record retention.

(b) Record retention. (1) Any person subject to the Act and this part shall retain evidence of compliance with the requirements imposed by the Act and this part 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.

Answer: 

Answer from Andy: Randy gave you Reg E requirements. Two considerations are 1) if your state law is more restrictive we won't know as we are not familiar with all the states, and 2) applications for debit card are not required in the first place and would not require retention unless you are making required disclosures on them.

First published on BankersOnline.com 7/16/12

First published on 07/16/2012

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