A creditor maintains ordinary Regulation Z compliance evidence, TRID documentation, and completed Closing Disclosures. Which retention approach is correct?
Correct Answer
D) Apply the relevant two-, three- and five-year periods, plus any longer applicable requirement
D. Apply the record-specific periods and any longer applicable requirements. Ordinary covered evidence: two years after required disclosure or action. Covered TRID evidence: three years after the latest of consummation, required disclosure or required action, subject to the Closing Disclosure exception. Completed Closing Disclosures and related documents: five years after consummation. Scope and exceptions: These are not universal deletion dates. Advertising is excluded from the general rule; other categories and longer obligations require separate checks. Source: Section 1026.25(a), (c)(1)(i)–(ii) — https://www.consumerfinance.gov/rules-policy/regulations/1026/25/
Why This Is the Correct Answer
D. Apply the record-specific periods and any longer applicable requirements. Ordinary covered evidence: two years after required disclosure or action. Covered TRID evidence: three years after the latest of consummation, required disclosure or required action, subject to the Closing Disclosure exception. Completed Closing Disclosures and related documents: five years after consummation. Scope and exceptions: These are not universal deletion dates. Advertising is excluded from the general rule; other categories and longer obligations require separate checks.
Why the Other Options Are Wrong
Option A: Keep all TRID compliance evidence for three years, including the completed Closing Disclosure
It overlooks the five-year Closing Disclosure rule.
Option B: Retain every mortgage document five years from application, without regard to required action dates
Application is not the universal trigger.
Option C: Apply the general two-year rule to the completed Closing Disclosure as well
The general rule does not override the special rule.
Exam Tip
Record category and starting event both determine retention.
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