Website Changes & Website Record Retention

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Question:

With regard to website changes (disclosures, marketing advertisements, general changes, etc.) is there a concrete retention schedule or best practices for retention? I see many companies treat these changes like a hard copy advertisement change. They will print out the archived page and save it for the examiner. If this is the case, is there a time frame to keep these archived print outs or do you just save them between examinations? I couldn't find any information on the FFIEC website that explains a policy and any website research is very vague.

Answer:

The time period for retention is the same as what you have done with traditional printed ads. In many ways you can be thankful there are no separate rules for e-retention as opposed to hard copy items. You need not save your web pages in printed form, but can retain them electronically if desired. You just need to be able to access them and show them to your regulator, if requested. Reg Z has no advertising retention requirement, but exam to exam is a common retention standard to prove compliance. Reg DD, the other major record retention requirement, says you'll keep ad documents for two years.

First published on BankersOnline.com 9/07/09