There’s no requirement to retain a copy (just need to demonstrate compliance). The NTHLA shows in the document print history for our home equity loans so we don't keep copies in file. Our first mortgages, however, utilize a different loan origination software program and the document doesn’t appear in the print history. The mortgage officers retain a copy of the NTHLA in the file (heck, they keep copies of everything in those files). As long as your procedures and practices are well documented and officers are fully trained, then--IMO--you’ll save yourself a lot of grief by removing the retention requirement from your procedures.
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No, I didn't lose my mind. It got scared and ran away.