We are looking at a new consumer origination system that cannot reproduce a copy of an adverse action letter after it has been system generated and sent to the applicant. We would have to keep and file, or image a copy of the letter sent. Our past system could re-create the letter on demand. This new system will produce a batch listing of the date, borrower, and denial reasons. Have any of you been through an exam with this limitation? Is the batch printout listing of information acceptable to the examiners? The retention section of Reg B says to "retain in original form or a copy thereof".

I think you should be OK. Here is the applicable comment from the OSC:

12(b) Preservation of records.
1. Copies. Copies of the original record include carbon copies, photocopies, microfilm or microfiche copies, or copies produced by any other accurate retrieval system, such as documents stored and reproduced by computer. A creditor that uses a computerized or mechanized system need not keep a paper copy of a document (for example, of an adverse action notice) if it can regenerate all pertinent information in a timely manner for examination or other purposes.


The borrower name, date sent and the reasons for denial should be enough to regenerate the notice by hand, even though it will not be a copy of the notice actually sent.