Compliance document archive maintained
Why it matters
SOX §802 imposes criminal liability for knowingly destroying or falsifying records that are "made or kept in connection with" a financial transaction — a standard that courts have applied broadly to financial service documents, not just audit records. ISO 27001:2022 A.5.28 independently mandates preservation of evidence for legal proceedings. For fintech products, compliance document archives are the primary evidence in CFPB examinations, FTC investigations, and customer disputes. A company that operates a financial product but maintains only the current version of its Terms and Privacy Policy has no ability to prove what disclosures a user accepted at the time of signup — a critical gap in any dispute resolution or regulatory examination.
Severity rationale
Low because compliance archives are a defense-in-depth control rather than a direct user-facing disclosure, but their absence makes legal disputes and regulatory examinations significantly harder to defend.
Remediation
Implement a versioned legal document archive at app/legal/archive/page.tsx. Store historical PDFs or versioned HTML in public/legal/ and index them with effective dates:
// app/legal/archive/page.tsx
const termsHistory = [
{ version: '2.1', effectiveDate: '2024-02-01', href: '/legal/terms-v2.1.pdf' },
{ version: '2.0', effectiveDate: '2023-06-15', href: '/legal/terms-v2.0.pdf' },
]
export default function LegalArchive() {
return (
<section>
<h1>Legal Document Archive</h1>
<h2>Terms & Conditions</h2>
<ul>
{termsHistory.map(({ version, effectiveDate, href }) => (
<li key={version}>
<a href={href}>Version {version}</a> — effective {effectiveDate}
</li>
))}
</ul>
</section>
)
}
At minimum, archive Terms, Privacy Policy, and any fee schedules. Link the archive from the footer alongside current documents.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the Regulatory Disclosure Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- sox · §802 — SOX §802 — document retention requirements for financial records
- iso-27001:2022 · A.5.28 — ISO 27001:2022 A.5.28 — collection of evidence; document retention
Taxons
History
- 2026-04-18·v1.0.0·Initial import from finserv-disclosure·automated