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How long do we have to keep call recordings and SOAs? Does the same rule apply to permission to contact?

Call recordings must be kept for 6 years. The excerpts don't address a retention period for Scope of Appointment (SOA) forms or Permission to Contact records, so I can't confirm whether the same 6-year rule applies to those.

What the rule says

On call recording retention:

“All marketing and sales calls, including the audio portion of calls conducted via web-based technology, must be recorded and retained in their entirety for a minimum period of 6 years.”
42 CFR § 422.2274(g)(2)(ii) / § 423.2274(g)(2)(ii)
“For the first 3 years of the retention period, records must be maintained in audio format. For years 4, 5, and 6, records may be maintained in either audio format or as complete and accurate transcript recordings.”
42 CFR § 422.2274(g)(2)(ii) / § 423.2274(g)(2)(ii)

On the Scope of Appointment itself, the excerpts describe when it must be obtained and how long its *scope* remains valid, but not a document retention period:

“Prior to the personal marketing appointment, the MA plan (or agent or broker, as applicable) must agree upon and record the Scope of Appointment with the beneficiary(ies).”
42 CFR § 422.2264(c)(3)(i) / § 423.2264(c)(3)(i)
“Market any health care related product during a marketing appointment beyond the scope agreed upon by the beneficiary, and documented by the plan in a Scope of Appointment, business reply card, or request to receive additional information, which is valid for 12 months following the date of beneficiary's signature date or the date of the beneficiary's initial request for information.”
42 CFR § 422.2264(c)(3)(iii)(A) / § 423.2264(c)(3)(iii)(A)

That 12-month figure is a validity period for what topics may be discussed, not a record-retention requirement.

The excerpts do not contain a retention-period requirement for SOA forms or for "Permission to Contact" records, and do not state whether the 6-year call-recording retention rule extends to those documents. This was searched in 42 CFR §§ 422.2264(c), 423.2264(c), 422.2274(g), and 423.2274(g), the only TPMO/recordkeeping and event provisions supplied.

Carrier and FMO rules are often stricter than CMS rules. This tool reports what CMS sources say and is not legal advice. Enrollment guidance shown is the CY 2027 version. Regulation text reflects the CY 2027 marketing rules, which apply to marketing beginning October 1, 2026.

This answer was generated by mapdbot from the sources listed below on September 23, 2026 and checked against them. Regulation text: eCFR as of 09/15/2026. It is for licensed insurance agents, is not legal advice, and does not cover carrier or FMO rules.

Sources cited

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