Regulation DD, which implements the Truth in Savings Act, requires financial institutions to “retain evidence of compliance . . .  for a minimum of two years after the date disclosures are required to be made or action is required to be taken.” Regulation DD’s Official Interpretations mention microfiche only to state that “[r]ecords evidencing compliance may be retained on microfilm, microfiche, or by other methods that reproduce records accurately.” Consequently, we believe microfiche that contains evidence of your institution’s compliance with Regulation DD may be disposed of after a minimum of two years.

For resources related to our guidance, please see:

• Regulation DD, 12 CFR 1030.9(c) (“A depository institution shall retain evidence of compliance with this part for a minimum of two years after the date disclosures are required to be made or action is required to be taken. The administrative agencies responsible for enforcing this part may require depository institutions under their jurisdiction to retain records for a longer period if necessary to carry out their enforcement responsibilities under section 270 of the act.”)

• Regulation DD, Official Interpretations, Paragraph 9(c), Comment 2 (“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).”)