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COMPLIANCE CALENDAR
OCTOBER
- BSA training is an annual requirement. Be sure that you train everyone who needs it. That includes almost everyone. Make the training fun. Have people come dressed as a suspicious activity!
- October 28th is the 29th anniversary of Regulation B. Use the anniversary to schedule training, including signature requirements and adverse action notices.
- October 28th and Check 21 hits.
NOVEMBER
- This is when bears hibernate. Don't you wish you could too?
- Comments on the Federal Reserve's proposal to revise Regulation E are due by November 19, 2004.
- The year for HMDA LARs reporting will soon be over. You can expect lots of errors. If you haven't already done so, get serious about checking the quality of the LAR data. If you find errors, fix the errors and the process now.
- Check on the CRA data to see how that information is coming and what type of story it tells.
DECEMBER
- Get ready. Hear comes the FACT Act! Major proposals and final rules should be out by now - or very soon.
- Think positive thoughts. Review your accomplishments for the year. It has been a big year for compliance and you have accomplished more than you think.
- Good work should not go unnoticed. Thank staff for their efforts to support compliance. As the song says, accentuate the positive.
- Watch the Federal Register or BankersOnline (much more interesting) for proposals from the regulatory agencies. The last two weeks of December are often busy ones. There is usually an update on Regulation Z and the Commentary.
JANUARY
- Start off the year with a gift for tellers to help them with Regulation CC. Provide them with cards that show local area routing numbers. Be sure that you have any new local routing numbers that result from the FRB's consolidations.
- Look over your training calendar for the year. Schedule all needed training and don't let anyone cut class.
- Round up the HMDA data from last year and start scrubbing.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 11, 10/04
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