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#509901 - 03/08/06 02:30 PM HMDA Retention - Denials
ECMC7 Offline
Junior Member
Joined: Sep 2005
Posts: 46
Denied and Withdrawn applications that are HMDA reportable. Are these OK to destroy after 25 months, or must they be kept as support for the retention period for the HMDA LAR?

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Lending Compliance
#509902 - 03/08/06 03:06 PM Re: HMDA Retention - Denials
sue's mom Offline
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sue's mom
Joined: Feb 2003
Posts: 455
IL
These must be kept for the HMDA LAR retention period. I believe that is five years.

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#509903 - 03/08/06 03:24 PM Re: HMDA Retention - Denials
Sooner Fan Offline
100 Club
Joined: May 2005
Posts: 220
Where the wind blows swiftly d...
W/all due respect, what are you basing your answer on? I think HMDA adverse action notices only have to be kept for 25 months as w/any adverse action notices, but maybe I'm wrong.

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#509904 - 03/08/06 03:27 PM Re: HMDA Retention - Denials
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
I just had to look this up as I had a similar question yesterday. On page C-6 of the GIR, it states to retain for 3 years.

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#509905 - 03/08/06 03:27 PM Re: HMDA Retention - Denials
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The HMDA retention rules only apply to the required disclosures.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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