Hello all,

Has anyone found in IRS regs/documentation support for the below footnote found in AACRAO Retention Schedule A, which talks about a 3 year (as opposed to 1 year) retention of records of un-enrolled/un-accepted student records at private institutions:

"Notes:

1. Although the retention period recommended for the documents listed above is one year, federal legislation, state statutes, or institutional
policy may dictate otherwise. The federal legislation which governs these records is as follows:

* The IRS requires that, for tax-exempt status for private institutions, the records of applicants who apply and do not enter be retained for
three years

********
We've found in IRS 990 Schedule E this piece below on records/reports re: the  racial composition for student body, faculty staff-but nothing about un-accepted/un-enrolled data/records-any pointers or guidance would be much appreciated.

****************************

7.01 Specific records. Except as provided in section 7.03,
each exempt private school must maintain for a minimum
period of three years, beginning with the year after the year
of compilation or acquisition, the following records for the
use of the Service on proper request:
1. Records indicating the racial composition of the student
body, faculty, and administrative staff for each academic
year.
2. Records sufficient to document that scholarship and
other financial assistance is awarded on a racially
nondiscriminatory basis.
3. Copies of all brochures, catalogues, and advertising
dealing with student admissions, programs, and
scholarships. Schools advertising nationally or in a large
geographic segment or segments of the United States need
only maintain a record sufficient to indicate when and in what
publications their advertisements were placed.
4. Copies of all materials used by or on behalf of the
school to solicit contributions.


*************
David Read
University Records Manager

University of Denver
University Records Management Program
Penrose Library, RM 327
[log in to unmask]
303.871.3334
http://library.du.edu/urmp




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