Thread Options
#2077493 - 05/06/16 07:13 PM Record Retention on Non-originated TRID Loans
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094

(c)(1) Records related to requirements for loans secured by real property. (i) General rule. Except as provided under paragraph (c)(1)(ii) [CD] of this section, a creditor shall retain evidence of compliance with the requirements of 1026.19(e) [LE] and (f) [CD] for three years after the later of the date of consummation, the date disclosures are required to be made, or the date the action is required to be taken.

For a loan that is not originated (denied, withdrawn etc) TRID record retention is 3 yrs after the date disclosures are required to be made or date action was required to have been taken, correct? Or am I missing something?
_________________________
Opinions are my own and not of my employer.

Return to Top
Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2077498 - 05/06/16 07:28 PM Re: Record Retention on Non-originated TRID Loans ahou
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,209
Galveston, TX
missing something? No.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2077506 - 05/06/16 07:44 PM Re: Record Retention on Non-originated TRID Loans ahou
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
Thanks for the confirmation. Employees hate change smile
_________________________
Opinions are my own and not of my employer.

Return to Top
#2077881 - 05/10/16 05:15 PM Re: Record Retention on Non-originated TRID Loans ahou
NotDoneYet Offline
Gold Star
NotDoneYet
Joined: Jul 2010
Posts: 482
PA
Rlcarey, I thought I had determined a 2 yr retention for non-originated TRID loans based on page 1334 of the final rule. The first paragraph, second sentence: "However, the CFPB has decided to require creditors to retain evidence of compliance with the integrated disclosure provisions of Regulation Z for three years after consummation of the transaction, except..." And the Small Entity Guide also includes the words after consummation on page 16.
Apparently, I was going by what I believed was the intent of the rule instead of what it actually said in (c)(1)(i).
Good thing I still have time to contact our loan operations for proper retention of these documents.

Return to Top