Get ready. Hear comes the FACT Act! Any title that doesn't yet have rules should very soon. In the meantime, the identity theft flags take effect on December 1, 2004.
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. Find several people or projects that deserve special recognition.
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
Update high cost mortgage calculation forms to reflect the calculation base for 2005. The new cost is $510.
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.
Review the process for placing and tracking identity theft and active duty alerts. Get an early read on how it is working and whether any issues need to be addressed.
Round up the HMDA data from last year and start scrubbing. Look for any systemic errors that should be dealt with by the unit that made the error. Get the system and last year's data fixed the most efficient way.
FEBRUARY
Get the HMDA data in by the end of the month - or sooner. Be sure to do a quality and edit check before sending in your data.
If HMDA is under control, review your BSA exempt list. This should be updated next month. Be sure you have time to give appropriate attention to account activity of exempt customers.
MARCH
Update your BSA exemption list.
Watch for updates to the FRB Official Staff Commentaries, especially for Regulation Z.
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