Should a Financial Institution obtain a copy of the Sellers Closing Disclosure to keep in file?

Under 1026.19(f)(4). the settlement agent shall provide the copy, however it does not state that a Financial Institution shall retain a copy. I would think that we would have to review for our internal controls.

Thoughts?

1026.25(c) Records related to certain requirements for mortgage loans.

(1) Records related to requirements for loans secured by real property or a cooperative unit. (i) General rule. Except as provided under paragraph (c)(1)(ii) of this section, a creditor shall retain evidence of compliance with the requirements of § 1026.19(e) and (f) 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.

(ii) Closing disclosures. (A) A creditor shall retain each completed disclosure required under § 1026.19(f)(1)(i) or (f)(4)(i), and all documents related to such disclosures, for five years after consummation, notwithstanding paragraph (ii)(B) of this section.