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#2163151 - 02/05/18 08:53 PM Record Retention - Commercial Loans
BNH Offline
100 Club
BNH
Joined: Feb 2013
Posts: 108
Any guidance on commercial and consumer charged off loan files, paid loan files, adverse action files, etc. and their record retention time frame? I know a lot of documents within the files have specific record retention time frames but it would be easier if we could just have a retention time frame for the file as a whole.

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#2164860 - 02/16/18 05:04 AM Re: Record Retention - Commercial Loans BNH
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,307
Adverse action files are governed by the following section of Regulation B (ECOA). https://www.bankersonline.com/regulations/12-1002-012 Generally it is 25 months for consumer purpose credit and 12 months for business credit. See special provision in 1002.12(b)(5).
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#2164866 - 02/16/18 11:58 AM Re: Record Retention - Commercial Loans BNH
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
As for the other questions, it is a matter of State law and usually related to the statute of limitations for lawsuits. Check with your State Bankers Association - they usually publish retention schedules.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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