Website Screen Record Retention

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Question:

Is it a requirement under Reg DD record retention to retain your website screens for two years? I read an article that said as website screens (pages) are generally a large advertisement for loan and deposit products, they should be retained under Reg DD for a two year period on a zip disc, CD, DVD or hard copy. I am currently working on an advertising audit for my bank and I wanted to make sure that this is accurate.

Answer:

If the web page is an advertisement, the applicable regulations will apply. That includes the retention rules under the respective regulations for applications, advertisements and anything else that you would retain had this been paper. Reg DD, which will apply to your deposit products, requires a two year retention under Section 230.9 (c). This applies whether it is a web page or a newspaper page.

First published on BankersOnline.com 9/15/08