CREDFIXLY RECORD RETENTION AND DESTRUCTION POLICY  

1)     Purpose

The purpose of this Policy is to ensure that necessary records and documents of Credfixly, are adequately protected and maintained and to ensure that records that are no longer needed by Credfixly or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of our company in understanding their obligations in retaining electronic documents - including e-mail, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.

2)     Policy

This Policy represents Credfixly’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

3)     Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Credfixly and the retention and disposal schedule of electronic documents. The President is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The President is also authorized to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for Credfixly, ; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

4)     Suspension of Record Disposal

In Event of Litigation or Claims In the event Credfixly is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning Credfixly, or the commencement of any litigation against or concerning our company, such employee shall inform owner/management and any further disposal of documents shall be suspended until shall time as the management, with the advice of counsel, determines otherwise. The owner/management shall take such steps as are necessary to promptly inform all staff of any suspension in the further disposal of documents.

5)     Applicability

This Policy applies to all physical records generated in the course of the credit repair company’s operation, including both original documents and reproductions. It does not apply to independent contractor records as we rely upon the governing boards of third party vendors to set appropriate retention policies for their members. It also applies to the electronic or digital documents described above. This Policy was approved by the President of Credfixly.

APPENDIX A ‑ RECORD RETENTION SCHEDULE

The Record Retention Schedule is organized as follows:  

SECTION TOPIC  

A.       Accounting and Finance

B.        Contracts and Memorandums of Understanding

C.        Corporate Records

D.       Correspondence and Internal Memoranda

E.        Electronic Documents

F.        Legal Files and Papers

G.       Miscellaneous

H.       Personnel Records

I.          Property Records

J.         Tax Records

K.       Contribution Records    

A.       ACCOUNTING AND FINANCE  

Record Type Retention Period

Accounts Payable ledgers and schedules 7 years

Accounts Receivable ledgers and schedules 7 years

Annual Audit Reports and Financial Statements Permanent

Annual Audit Records, including work papers and other documents that relate to the audit 7 years after completion of audit

Annual Plans and Budgets 2 years

Bank Statements and Canceled Checks 7 years

Employee Expense Reports 7 years

General Ledgers Permanent

Interim Financial Statements 7 years

Notes Receivable ledgers and schedules 7 years

Investment Records 7 years after sale of investment

Internal Audit work papers and findings 7 years after completion

    B.        CONTRACTS  

Record Type Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supporting documentation) 7 years after expiration or termination  

    C.       CORPORATE RECORDS  

Record Type Retention Period

Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports) Permanent

Bond, Licenses and Permits Permanent

Memorandums of Understanding Permanent

  D.       CORRESPONDENCE AND INTERNAL MEMORANDA  

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.  

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:  

1.      Those pertaining to routine matters and having no significant, lasting consequences should be discarded within two years. Some examples include:  

·     Routine letters and notes that require no acknowledgment or follow‑up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.

·     Form letters that require no follow‑up.

·     Letters of general inquiry and replies that complete a cycle of correspondence.

·     Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).

·     Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.

·     Chronological correspondence files.  

Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.  

2.      Those pertaining to non‑routine matters or having significant lasting consequences should generally be retained permanently.  

  E.        ELECTRONIC DOCUMENTS  

1.      Digital Credit Reports: Great care will be taken with customer’s private credit contents and should be retained and secure for 5 years after the file is closed.  

2.      Electronic Mail: Not all email needs to be retained, depending on the subject matter.

·     Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.

·     Staff will not store or transfer Credfixly related e-mail on non-work-related computers except as necessary or appropriate for company purposes.

·     Staff will take care not to send confidential/proprietary company information to outside sources.

·     Any e-mail staff deems vital to the performance of their job should be copied to the staff’s thumb drive.  

3.      Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter.

·     PDF documents – The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The maximum period that a PDF file should be retained is 6 years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employee’s workspace.

·     Text/formatted files - Staff will conduct annual reviews of all text/formatted files (e.g., Microsoft Word documents) and will delete all those they consider unnecessary or outdated. After five years, all text files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staff’s workspace.

4.      Web Page Files: Internet Cookies

·     All workstations: Internet Explorer should be scheduled to delete Internet cookies once per month.  

Credfixly does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.    

F.        LEGAL FILES AND PAPERS  

Record Type Retention Period

Legal Memoranda and Opinions (including all subject matter files) 10 years after close of matter Litigation

Files 10 year after expiration of appeals or time for filing appeals

Court Orders Permanent

Requests for Departure from Records Retention Plan 10 years
 
  G.       MISCELLANEOUS  

Record Type Retention Period

Consultant's Reports 2 years Material of Historical Value (including pictures, publications) Permanent

Policy and Procedures Manuals – Original Current version with revision history

Policy and Procedures Manuals ‑ Copies Retain current version only Annual Reports Permanent

    H.       PERSONNEL RECORDS  

Record Type Retention Period

Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records) 6 years after separation    

Employment Contracts – Individual 7 years after separation  

 
    I.         PROPERTY RECORDS  

Record Type Retention Period    

Correspondence, Property Deeds, Assessments, Licenses, Rights of Way Permanent    

Original Purchase/Sale/Lease Agreement Permanent    

Property Insurance Policies Permanent

    J.         TAX RECORDS  

General Principle: Credfixly must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.  

These documents and records shall be kept for as long as the contents thereof may become material in the administration of federal, state, and local income, franchise, and property tax laws.  

Record Type Retention Period    

IRS Rulings Permanent Excise Tax Records 7 years

Tax Bills, Receipts, Statements 7 years

Tax Returns ‑ Income, Franchise, Property Permanent Tax Workpaper Packages ‑ Originals 7 years

Sales/Use Tax Records 7 years

Annual Information Returns - Federal and State Permanent IRS or other Government Audit Records Permanent

    K.       CONTRIBUTION RECORDS  

Record Type Retention Period

Records of Contributions Permanent My Credit Repair Company’s or other documents evidencing terms of gifts Permanent
     

The President of Credfixly, adopts this statement of record retention policies.  

Roger Da Silva, President of Credfixly LLC. 05/18/2024