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Subject:
From:
David Gaynon <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 18 Mar 2009 08:18:15 -0700
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 Bruce

Thanks for passing along the information.  I would just warn my colleagues that state regulations can get a little tricky.  I have referenced one from Illinois below.

http://www.ilga.gov/commission/jcar/admincode/038/038010500J11750R.html

If you read this you will see that there is generally no problem with imaging and destroying the hard copy provided you meet certain documentation criteria. However if you look at section of b2 --the last sentence in this section states: "A mortgage banker licensee shall maintain all required original documents in hard copy or paper-based form and shall retain hard copies or paper-based documents for all loans assigned to another mortgage banker licensee or entity."

If you carefully reread this paragraph you may come to the conclusion that there is some ambiguity with reference to requirements.  That is why I would always want to get legal input on such a question.

David Gaynon
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