The five-year record retention requirement for disclosures made under RESPA is measured from:

The five-year record retention requirement for disclosures made under the Real Estate Settlement Procedures Act (RESPA) is indeed measured from the date the loan is sold or paid off. This is significant because it emphasizes that lenders and servicers must maintain records related to the transaction for a substantial period, extending beyond merely the closing date or application date.

The rationale behind this timeframe aligns with the potential for audits, inquiries, or disputes that may arise after the loan has been closed. Keeping records until the loan is sold or paid off ensures that there is ample documentation available to address any questions about the terms of the loan, the disclosures made, and compliance with the regulations set forth under RESPA. By maintaining these records for a full five years after the loan's lifecycle concludes, it assures consumers that their rights can be protected with appropriate documentation available. This requirement reflects the importance of transparency and accountability in the mortgage servicing industry.