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Retention for Hold Notice/Funds Availability Form

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Question: 
Can anyone tell me what the retention period is for hold notices/funds availability forms? I have checked with our state bank department and this form was not specifically addressed. If it is not uniformly required, how long do other banks keep these Reg CC notices, and what about cash advance receipts (Visa)?
Answer: 

Randy Carey:
Official Interpretation
G. 229.21(g) Record Retention
1. Banks must keep records to show compliance with the requirements of this subpart for at least two years. This record retention period is extended in the case of civil actions and enforcement proceedings. Generally, a bank is not required to retain records showing that it actually has given disclosures or notices required by this subpart to each customer, but it must retain evidence demonstrating that its procedures reasonably ensure the customers' receipt of the required disclosures and notices. A bank must, however, retain a copy of each notice provided pursuant to its use of the reasonable cause exception under §229.13(g) as well as a brief description of the facts giving rise to the availability of that exception.

Answer: 

Brian Crow:
Visa requires transaction receipts to be retained for the period of time that a transaction is subject to a chargeback.

5.9.2.1 Transaction Receipt Retention Period
For Transactions in which a Merchant or Acquirer must obtain Cardholder signature, the Merchant or Acquirer must retain a Transaction Receipt for a minimum of 120 calendar days after the Processing Date.

First published on 07/11/2021

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