Were the record retention requirements under Regulation B changed by the Dodd-Frank Act?

We were recently asked this question about the Dodd-Frank Act by one of our credit union clients and thought the information would be helpful to others who may have similar questions.

The Dodd-Frank Act made specific changes to the sections of the Equal Credit Opportunity Act (ECOA) and Regulation B that pertain to the statute of limitation for civil actions and actions brought by an Attorney General.  The Dodd-Frank Act increased the statute of limitation for these actions from two years to five years.

However, the Dodd-Frank Act did not make any changes to the record retention requirements, which are addressed in separate sections of ECOA and Regulation B.

The minimum record retention requirement for documents evidencing compliance with ECOA and Regulation B (loan applications, any documents relied on for the loan decision, adverse action notices, etc.) still remains at 25 months for consumer loans and 12 months for commercial loans.

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