From what I can find the HMDA LAR retention is 3 years. We have had a question come up as to whether this means we need to keep our Adverse actions that are HMDA reportable for that 3 years period as well instead of the normal 25 months. Does anyone know where I could find the answer or a good reference to prove an anwser? From what I can find the HMDA requirement is strictly for the HMDA Lar it adds no retention time to the AA files but of course I could be wrong. I can't find anything that specifically addresses HMDA reportable AAs.

There is no need to keep the HMDA-reportable applications longer than 25 months. As long as you keep the LAR for three years you are OK. I don't know exactly where to find this in writing anywhere, though, except that the Getting It Right guide only talks about having to keep the LAR.