Fall Regulatory Summit

Internal Use Only

If your agency’s record retention is greater than ten years and your agency can receive data downloads, would your agency be more likely to agree to the ten-year record retention recommendation? (Slide only shows those with record retention policy of ten years or more (including indefinite)).

CURRENT USE OF DATA DOWNLOADS

“YES” RESPONDENTS V. PROPOSAL

"NO" RESPONDENTS V. PROPOSAL

No, 3

N/A, 4

Yes, 5

N/A, 3

No, 1

Yes, 10

Internal Use Only

Where are we now?

What other data points should be a part of the record retention policy? Testing is good for five years. Should we change the policy to say five years from the date of the last test or ten years, whichever occurs later? What about regulatory actions? Do they make a difference? How long should the purge pause or extend?

CSBS recommends that NMLS have a ten-year record retention policy, which is to begin the date that the licensee no longer has a valid license or maintains a registration on the system. At the end of the retention period agencies will have the opportunity to download certain pre-identified data points before they are purged from the system. The record retention policy will include a litigation hold.

What are we missing?

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