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Record Retention for Deposit Denials

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Question: 
Are we required to retain applications or signature cards for denied deposit accounts?
Answer: 

Since this relates to deposit accounts, Regulation B would not come into play, only FCRA. FCRA does not have any record retention requirements regarding denials; however, I would keep the credit report/score so you have a way to prove that the credit report/score led to the denial. Some documentation of the deposit account application might be a good idea, as well, because it will help show why you pulled a credit report. Again, this is recommended, but not required.
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First published on 10/29/2017

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