The renewal terms will be disclosed in the notification required by 1030.5(b).

Is it best practice to keep the re-disclosure of the TIS for these CDs that are auto renewing and over a year old? Some are saying it's not necessary to image the re-disclosure due to our procedures indicating that we are mailing the re-disclosure, along with the renewal notice, to the customer. Some others feel it's best to image the re-disclosure to prove that we did produce it.

Also, how are others handling CDs that are 1 year? Should these CDs fall in with the CDs that are over a year? Better to disclose than not.

OFFICIAL INTERPRETATION OF SECTION
Section 1030.9--Enforcement and Record Retention
(c) Record retention.

2. Methods of retaining evidence. Institutions must be able to reconstruct the required disclosures or other actions. They need not keep disclosures or other business records in hard copy. Records evidencing compliance may be retained on microfilm, microfiche, or by other methods that reproduce records accurately (including computer files).

CD maturities of one year or less but longer than one month fall under 1030.5(b)(2)