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Loan App Retention

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If we take a loan app over the phone, web page or in person, how long do we have to keep each?

Reg B requires you’ll keep the consumer apps for 25 months and commercial apps for 12. Be sure that you think beyond that document that is the “Application” as retention goes beyond that. Any application that the bank receives, which includes any information required to be obtained concerning characteristics of the applicant to monitor compliance with the ECOA or other similar law, and any other written or recorded information used in evaluating the application and not returned to the applicant at the applicant's request must be retained. And the bank should consider retaining copies of what an applicant wants returned.

Learn more about Andy Zavoina’s webinar
Applications and Applicants – What you must know

First published on 08/19/2018

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