Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#942534 - 04/15/08 08:22 PM adverse action record retention
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 448
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.

Return to Top
#942560 - 04/15/08 08:47 PM Re: adverse action record retention complyorelse
Steve Doty Offline
100 Club
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)

Return to Top
#947087 - 04/22/08 12:34 PM Re: adverse action record retention Steve Doty
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 448
U.S.
Does this apply to HMDA reportable applications or should those be retained for a longer period?

Return to Top
#947123 - 04/22/08 01:18 PM Re: adverse action record retention complyorelse
Tigg Offline
Power Poster
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!
_________________________
What would you do if you knew you could not fail? ~ Dr. R Schuller

My opinion only.

Return to Top

Moderator:  Lestie G