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Adverse Action- File a Copy of the FCAI Disclosure

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Do we need to keep a copy of the Federal Credit Application Insurance Disclosure in our files when an adverse action notice is sent to a customer for a consumer loan?

The regulation (12 CFR 208.84 if you are a FRB regulated bank) states what you must disclose and when that information must be disclosed, but not how long evidence of compliance must be retained. Reg B (202.12(b)) does stipulate that you must retain all documentation used in making an adverse credit decision for 25 months. Therefore, even if you did not take into consideration the applicant's decision to purchase or decline the offered insurance, it would be prudent to retain the FCAI disclosure for 25 months.

First published on 1/12/09

First published on 01/12/2009

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