I was recently working on a situation where we needed to see some old documents related to a file that was in controversy. After much pushing and pulling a third party produced personal identification, documents, and photographs that had originally been provided when that third party was an employee of a different institution. What were they doing with that information in their possession? Was this proper? Can you keep personal information about your past clients to include materials that could create a risk of identity theft for them or a potential abuse of their privacy?
I don’t think so. There might be some argument about regulatory record retention that you could try to rely on, but I believe the CFPB would look upon this as creating a consumer risk that actually had no purpose as an offset.
Now think, what’s in your “wallet”? Of course, I mean your storage files.
If you have any of this personal information, or have kept documents that should have been shredded after submission to your funding lender, I suggest you go to your storage facility and shred all of them right now. Keep only the file basics as required by state and federal law. Protect your client’s identity and privacy by shredding the supporting identification documentation.
Let me work for you, Give me a call at 800-557-6580. Knowledgeable and affordable. Over and out.