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Subject:
From:
Joanie Erickson <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Thu, 28 Sep 2017 15:06:16 -0400
Content-Type:
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Hey there.  I am hoping you might be able to give some insight to a si
situation that we are having.  

We have employees at a facility that are relocating.  We own the current 
building and have a leased floor to a mortgage company that went belly-up 
recently.  This property comes under our control tomorrow.  When doing a 
walk-thru of the floor they found records with personal information.  They wa
want guidance on what to do with those records and if they are responsible fo
for them.   I told them I would get back to them soon after I did some re
research.

My gut opinion is that we become the unintentional owner/custodians of 
those records since we are the lease holder.  And that we need to handle 
them as if they were our own and do some kind of disposition.  Meaning if 
they need to be transferred to HUD or bankruptcy, disposal, or whatever.  I 
don’t want us to hang-on to them for the entire lifecycle but to put them in the
the proper hands.

Do you have any advice or knowledge in this area from the mortgage b
bubble?

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