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Rhode Island Adopts 5-Year Record Retention Rule for Debt Collectors

The Rhode Island Department of Business Regulation has adopted a record retention rule for debt collectors requiring that virtually all records be retained for a minimum of five years “following the transaction.”

Records that must be retained include the following:

  1. all audio recordings of contact with customers;
  2. records of all customers contacted;
  3. all written correspondence (including that sent electronically) between the licensee and the consumer;
  4. complete files and documentation of every debt the licensee has attempted to collect including any and all documents relating to that debt;
  5. all communications received from customers including copies of all documents received in hard copy or electronically and recordings of or notes regarding all conversations with consumers;
  6. all written notices sent to consumers; and
  7. any and all other documents created during or received by the licensee in the transaction of the business under the license.

The rule went into effect on Nov. 4, 2018.

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Eric Rosenkoetter is a principal at Maurice Wutscher LLP, where he provides counsel to businesses and consumer financial services firms nationwide. For many years, he has focused his practice on various aspects of financial services law. As a litigation attorney, he has conducted every aspect of the litigation process, including countless depositions, motion proceedings, bench and jury trials, and appeals in various courts. In addition, he has significant experience as a compliance and transactional attorney, providing strategic, business growth, legislative, compliance and regulatory advice to national corporations and trade associations. For example, he has drafted consumer contracts and disclosures designed to state-specific statutory requirements, and developed “Best Practices” guides and state-by-state compliance grids, for national financial services companies. He also conducted research and crafted a metrics report for a national trade association with analysis designed to counter the claims of advocacy groups. Eric’s experience also includes working for a national corporation as Executive Counsel, Chief Compliance and Ethics Officer, and Director of Legislative Affairs, and as a federal lobbyist and Director of Government and Public Affairs for a national financial services trade association. In the government sector, Eric presided over approximately 6,000 state administrative hearings, served as a staff attorney for the Missouri Senate, and handled litigation in 33 counties as a regional managing attorney. Eric frequently speaks to audiences on topics relevant to the financial services industry including regulatory compliance, data privacy law and related advocacy initiatives. For more information, see

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