A school must document a student's withdrawal date and maintain that documentation as of the date of the school's determination that the student withdrew. A school that is not required to take attendance should use the last date of attendance at an academically related activity as a student's withdrawal date. As with other Title IV program records, documentation must be retained and available for examination in accordance with the regulatory provisions for recordkeeping (34 CFR 668.24); (34 CFR 668.22(c)(3)).