Retention and deletion

An install keeps a loan’s files only while the loan is worked. An open loan is never deleted on a timer: its files go when the loan officer closes the loan, or after 90 days untouched, and your shop can set its own number.

While the loan is worked

The install holds what the work points at, so a source page opens and an evidence crop renders while the loan is being worked:

• the copies of the documents and their page images
• the text read from each page, with the position of every word
• the facts read from them, the loan’s state and its findings
• each calculation, each structure tried and each AUS result

All of it is encrypted under your keys in your own storage account, and none of it leaves your tenant.

When it is deleted

Any activity on a loan, a new document, an AUS run or an officer opening it, starts the count again.

What stays afterwards

• The results, in your LOS. The structure, the result PDF with its evidence and citations, and the conditions were written into your LOS as the loan was worked. They are your file, kept under your own retention.
• A de-identified record of what was tried. Which change was tried for which finding, and what the AUS said next. No name, address, Social Security number, document, page or text. It stays in your tenant and teaches your install which fix to try first. It reaches no other lender unless your shop gives written permission.
• The record of the deletion itself. What was deleted, when, and whether a person or the rule did it.

For the Safeguards Rule

The rule asks that customer information is disposed of no later than two years after it was last used (16 CFR 314.4(c)(6)). An install’s working copies are gone when the loan closes or within the number of days your shop sets.