Are pre-qualification requests required to be kept a certain amount of time? Are they subject to the 25 month record retention rule?

We consider ours to be applications for credit and we do access a credit report. So we record-retain for 25 months. Actually, the applications are retained "forever" in the Bank's imaging system.

Actually, the applications are retained "forever" in the Bank's imaging system.

That is a very, very dangerous thing to do.

That is why I put "" around the word "forever".....should have put a winky face too. We DO still retain the paper.

I was not referring to imaging, I was referring to the forever part. It is one thing to play Russian roulette with one bullet but that keeps the gun fully loaded.

Oh....I'm not good at reading between the lines. Are you meaning that the records should be deleted after 25 months?

Well, for instance, let's say you find yourself under a claim of discrimination during a fair lending review which results in a referral to the DOJ. You think that they are going to cap the discovery to 25 months of applications when you have applications going back for years?

Good point. I have worked at three banks. None of them delete imaged records.

I have worked at multiple institutions and all of them struggled with deleting imaged records, but they all acknowledged that permanent retention was a problem...It is an issue that can be difficult to get management's attention or should I say resources for.

The question would be why would you image applications that do not result in an origination anyway??

Randy brings up a good point. I'm very much in the camp that you don't need to image denials, withdrawals, etc.

The old saying is "bankers keep everything for ever" but that's not a prudent practice. You do want to ensure that you keep things to satisfy all regulations, however. For instance, you can't destroy non-originated applications after 25 months if it was an application subject to HMDA. You need to keep everything to support all entires on the LAR for 3 years following submission. That could be up to 4 ¼ years from when you denied/withdrawn/closed it.