Record Retention on Non-originated TRID Loans

Posted By: ahou

Record Retention on Non-originated TRID Loans - 05/06/16 07:13 PM


(c)(1) Records related to requirements for loans secured by real property. (i) General rule. Except as provided under paragraph (c)(1)(ii) [CD] of this section, a creditor shall retain evidence of compliance with the requirements of 1026.19(e) [LE] and (f) [CD] for three years after the later of the date of consummation, the date disclosures are required to be made, or the date the action is required to be taken.

For a loan that is not originated (denied, withdrawn etc) TRID record retention is 3 yrs after the date disclosures are required to be made or date action was required to have been taken, correct? Or am I missing something?
Posted By: rlcarey

Re: Record Retention on Non-originated TRID Loans - 05/06/16 07:28 PM

missing something? No.
Posted By: ahou

Re: Record Retention on Non-originated TRID Loans - 05/06/16 07:44 PM

Thanks for the confirmation. Employees hate change smile
Posted By: NotDoneYet

Re: Record Retention on Non-originated TRID Loans - 05/10/16 05:15 PM

Rlcarey, I thought I had determined a 2 yr retention for non-originated TRID loans based on page 1334 of the final rule. The first paragraph, second sentence: "However, the CFPB has decided to require creditors to retain evidence of compliance with the integrated disclosure provisions of Regulation Z for three years after consummation of the transaction, except..." And the Small Entity Guide also includes the words after consummation on page 16.
Apparently, I was going by what I believed was the intent of the rule instead of what it actually said in (c)(1)(i).
Good thing I still have time to contact our loan operations for proper retention of these documents.