Retention

Retention

Answered by:

Question:

Does Reg Z require retention of advertisements, I don't see it? And do you know where Reg DD requires it?

Answer:

Reg Z does not have a retention requirement for advertising. It is exempted from 226.25, "A creditor shall retain evidence of compliance with this regulation (other than advertising requirements under Secs. 226.16 and 226.24) for 2 years..."

I would recommend keeping those ads for two years or from exam to exam, whichever is shorter. Just as you want them retained for your audits, so will your examiners.

Reg DD requires retention at Section 230.9(c) as it tells us "a minimum of two years after the date disclosures are required to be made or action is required to be taken."

First published on BankersOnline.com 11/7/11