We have begun the process of scanning our adverse action into the system.
I was just wondering what is a good time frame to keep the paper copy before shredding.
I know for Adverse actions the retention requirement is 25 mo and then 30 mos for hmda adverse actions.
If we have them uploaded in the system could we shred the originals in say like 60 days?

What's wrong with shredding them as soon as they are imaged and stored in a retrievable form? Better yet, if the system that generates to AAs can "print" an original to paper and a copy to file, skip the paper all together. Official Interpretation of Reg. B gives you great latitude in methods of retaining "copies."

Sorry, I meant the whole adverse action packet.
Including the signed documents.

I am not sure that imaging and then not deleting the images after the Reg B required record retention period is a smart move. If you have a problem, you are opening the door to an unlimited look-back if you have the records.

we shred originals as soon as we have confirmed the scanned copies are legible and retrievable. as far as record retention, our state banking department has a retention guide, as does AICPA and many others. We use those to set our retention, and when it expires, we delete. As Randy said, keeping past retention causes potential issues for the bank.

So as soon as I image the files and confirm that the files are imaged, I can shred the original packet immediately?

If you have a properly imaged file, what good are the paper copies?

Many regs go beyond the 25 month Reg B retention requirement. For instance, HMDA is 3 years from Submission. If you have an application in Jan 2019 that is subject to HMDA, you submit that info by March 2020 and then have to keep it until March 2023. That's 4 years and 2 months.

David, that is true, but the point is keeping anything longer than you have too is not really a good idea.

I agree Randy. But you need to think beyond Reg B's 25 month requirements (that's my point).

And I don't believe they need to keep paper copies. Electronic images are sufficient.

Thanks to everyone for answering. Thanks for pointing out the retention requirement also David.