Do we have to/should we have our clients sign/acknowledge that they received a copy our our new Privacy Notice that went into effect 2010? My question stems from a recent FDIC exam.
During a recent audit, I came across a consumer loan file where the application date and disclosures were not matching up. After questioning the lender, it turns out thethat customer initially applied for a HELOC, but then about a week later changed his mind about the product type, and went with a HE closed loan. I told the lender we should have kept the initial documentation for the HELOC in the file and noted that there was a product change on xx/xx/10, so that there would not be any questions on if the appropriate disclosures were provided to the customer. The lender stated that the application for the HELOC was withdrawn, so that documentation was not necessary to keep in the file. I didn't feel this was indeed a true withdrawn application on the initial product request. What do you think?
Do you know what the rules are for record retention for a participation loan that was purchased from another financial institution and has been paid off?
How long does the commercial lending department need to keep records of declines, withdrawals and paid loan files?
Do examiners expect to see a copy of the credit score disclosure (notice to home loan applicants) in the file of a denied application?
What is the record retention period for Credit Denials for state banks?
What is the record retention for real estate loan files and is it true that a bank must be able to recreate a loan for up to 10 years?
What are the requirements for e-mail record retention for banks?
How long should we retain the documents on a charged off loan, and when can it be deemed worthless? What needs to be done when it is deemed worthless?
During the next six to ten months, the FACT Act provisions will continue to take effect.