Adverse Action Retention

Posted By: Mel in WA

Adverse Action Retention - 12/16/15 12:44 AM

We are aware that Reg B requires declines/withdrawals be retained for 25 months. However, what if a Loan Estimate was issued and then the customer withdrew? Since the LE needs to be retained for 3 years, should we remove it and toss everything else related to the withdrawal? What is the risk of keeping the whole file for an additional 11 months?
Posted By: rlcarey

Re: Adverse Action Retention - 12/16/15 05:16 PM

1026.25(c)(1) Records related to requirements for loans secured by real property.

Notice it says loans, not applications.