COMPLIANCE CALENDAR
AUGUST
- FACT Act prescreening opt out notice rules took effect August 1, 2005.
- Schedule time for one of the federal agencies' BSA exam procedure briefings. Regional meetings will be held in 5 cities from August 15 - 24th. Visit the FRB's website for more information.
- HMDA data will be released some time this fall. Get ready. We already know what groups may be looking at. Do your own analysis first. Look at 2004 and the first six months of 2005.
- Schedule HMDA training. Design a training program that is directed at any weak points you have identified.
- Start watching for action on the CRA proposal. There might be something final by the end of the summer.
SEPTEMBER
- The new CRA rule affecting intermediate small banks takes effect on September 1, 2005. If your institution falls into this size range, look carefully at the revised regulation and then revise your CRA program.
- Check the status of regulatory publications from the Federal Reserve. Several rules, including Regulation E, are in process and may be published in late summer or early fall.
- OFAC reports on blocked or frozen assets are due on September 30. Check your accounts and prepare OFAC reports, if you have anything to report.
- September is a good month for Truth in Lending training. While there are no significant changes going into effect on October 1, you might as well stay on schedule with training.
- In preparation for commenting to the FDIC on deposit insurance for stored value cards, compile information on the number and nature of stored value cards that your institution may offer or handle. Consider the proposal's implications in the context of what information you do or do not have about the card holders.
OCTOBER
- Comments on the FDIC's stored value deposit card insurance proposal are due by mid-month. Get your comments in.
- Anniversary dates are always fun. There are several in October, including ECOA and CIP. This is a good time to schedule training on obtaining, storing and using customer information, including information that may be prohibited by Regulation B.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 9, 8/05
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