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#1656109 - 01/25/12 10:19 PM Skip-A-Pay Retention
Lilly1234 Offline
Member
Joined: Dec 2010
Posts: 50
Hello!
Does anyone know the retention on the coupons the customer signs for a skip-a-pay program? How long are we supposed to keep them? Are they comsidered extensions of credit so they should be 5 years? Or are they something else with a shorter time frame, like 2 years?
Thanks in advance!

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Lending Compliance
#1656122 - 01/25/12 10:29 PM Re: Skip-A-Pay Retention Lilly1234
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
I believe this is going to be a state law issue. SAP programs are typically governed by state law.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#1656123 - 01/25/12 10:30 PM Re: Skip-A-Pay Retention Lilly1234
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
You might check with your state association and see if they can answer your question.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#1656138 - 01/25/12 11:16 PM Re: Skip-A-Pay Retention Lilly1234
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
They represent a modification to the current loan. They should be retained for the normal retention period with all loan records, i.e., some period of time after pay-off as dictated by State law or statute of limitations.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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