My Bank has in its records a procedure to retain all of the pages which print from a Credit Bureau from the Bank's loan origination system for both commercial and consumer loans. This procedure was said to be in place for audit purposes.

However, the Bank's actual practice now differs from its procedure on both the commercial and the consumer side.

On the commercial side, the Notice to Home Loan Applicant prints on the last page of the Credit Bureau on some loans.
Because the NHLA is unnecessary on the commercial side, the loan assistant is asked to remove it from the credit bureau before origination.

On the consumer side, the risk based pricing notice prints at the end of the bureau. The Bank's loan origination system prints a separate risk based pricing notice from its system for the Bank's customer. To avoid duplication, the risk based pricing notice is removed from the credit bureau.

I am unaware of any regulatory requirement to retain a complete copy of a complete credit bureaus.

However, has anyone ever been questioned or cited for by auditors or examiners for incomplete credit bureaus?

I have never heard of it, but if this is routine, you are paying extra for this service, so why don't you just quit ordering them like this??

Thank you Randy, good point.

Perhaps your procedures were originally written prior to the Risk Based Pricing Rule (2010, I think). Your procedures for keeping "all pages" that print with a credit report may be due to Reg B retention requirements. I doubt extra copies of the notice were intended to be included in the procedure.