Answer:
The bank has few stated retention requirements under Reg. P.
If you provide notices electronically, you need to retain them and be able to provide them later, if requested, in written form. This period is not specified, however.
As to retaining a customer's opt-out notice, there is no requirement. Many banks allow opt-outs verbally and over the telephone systems. Some additionally allow e-mails,, and paper forms and the custmer may opt-out of one or many sharing opportunities. Retention would be nearly impossible under these circumstances and even more difficult to locate later.
Initially I would recommend archiving a hard copy of printed notices and an electronic copies of any Web site privacy notices. I would at least hold these from exam to exam. Since they won't take too much space, you should consider holding them longer in the event any litigation becomes "trendy".
First published on BankersOnline.com 7/9/01
print
share