Sold Loans

According to the new interagency guidance, if we sell a loan the account is considered "closed" for retention purposes. Does that also mean that if that individual comes in to open a new account a few months from now that they are no longer an existing customer if they had no other accounts except the sold loan? We do retain servicing rights on all sold loans.

That's the conclusion I would reach. They apparently don't consider servicing a loan to be an account. That does raise some interesting issues.