Is there any requirement on the length of time to retain customer authorizations to obtain credit reports in relation to opening deposit / loan account? The only retention periods I am aware of are 25 months for Reg B and 3 yrs for FRCA in relation to bank-initiated credit solicitations. It doesn't look like FCRA contains any retention periods in reference to customer-initiated requests?? Or would that strictly be something spelled out in the contract with the credit reporting agency?

Remember that technically a written authorization isn't needed, unless you have a state requirement to do so. So there is no retention period separate from maintaining what you used in your decision for Reg. B, on the loan side.

This post has been dead since 03' but I am bringing it back! Zombie topic!

We have an interesting situation that brought up the question...
Do we have to keep the actual credit report? Or can we just keep the score and adverse action notices with the reason for denial?

My initial thought after reading Reg B was yes, because the report was used in the decision. I just want to make sure I am not complicating what the reg requires (this will cost the Bank some money.

You can retain an electronic copy of the credit bureau. Many loan origination systems download the credit report electronically. if it is saved on the LOS, you are covered. I would take "and any other written or recorded information used in evaluating the application" to mean the credit bureau, since the regulators could try to reunderwrite/evaluate the application to the same criteria that the bank did.

That is our problem. We have the electronic version saved on our origination system that we are no longer using. Because we did not print the reports, we relied on the electronic version from that vendor. Since we are changing vendors, we will have to pay for them to send us the reports for us to retain.
Something to think about when changing vendors. It is a cost that is easy to look over.

What an unfortunate experience, but great lesson for all others. Thanks for posting it and for the warning.

I would document what you have, and put copies of whatever you currently have available, in the files. You still have the electronic retention however you are going to have to pay to retrieve it. The only files that could be an issue would be the ones between the last exam (or 25 months whichever is later) and when you changed processor).