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#942534 - 04/15/08 08:22 PM adverse action record retention
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Would someone mind confirming that we are required to maintain consumer adverse action notices/supporting documents for 25 months from the date of notification? (Business loans require less time.) I'm looking at 202.12 and this is how I am interpreting it.

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#942560 - 04/15/08 08:47 PM Re: adverse action record retention complyorelse
Steve Doty Offline
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Joined: Mar 2007
Posts: 137
Nebraska
You are correct, Adverse Action Notices (and all information used in the analysis of the application) must be retained for 25 months after teh applicant is notified 202.12(b)

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#947087 - 04/22/08 12:34 PM Re: adverse action record retention Steve Doty
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Does this apply to HMDA reportable applications or should those be retained for a longer period?

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#947123 - 04/22/08 01:18 PM Re: adverse action record retention complyorelse
Tigg Offline
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Tigg
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
I'm not aware of anything that requires you to keep HMDA reportable transactions longer, but I would tell you to make sure you definitely destroy your adverse actions as the reg states because the examiners are strict about not keeping these things around. They will check!
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