COMPLIANCE CALENDAR
DECEMBER, 2005
- Comments are due by December 16 on the Federal Reserve's second advance notice of rulemaking regarding the open end rules of Regulation Z.
- It is compliance recognition time. Find positive things to say and give recognition where staff has done well. The absence of violations should be positively noticed. Also give recognition to anyone who found a problem - and thus prevented more damage.
- Start the HMDA reporting process. Also take a look at your data. Compare 2005 information to 2004. Look at both in the context of issues raised when the 2004 data was released.
- It is not too soon to think about the coming medical information rule. Policies, procedures and training, should all be in place before April 1. Happy holidays!
- And while thinking about the medical information rule, think about the rest of the FACT Act compliance. December is FACT Act anniversary month and good time to do audits and take stock of the program.
JANUARY, 2006
- Comments on the proposed changes to the CRA Q&As are due to your regulatory agency by January 9, 2006.
- Get the Annual Reports on Indebtedness of Executive Officers and Principal Shareholders in before the end of the month.
- For the past several years, new compliance rules and issues have driven your job. Take some time at the beginning of this new year to review your program and set your own agenda. Focus attention where it is needed most.
- This months marks the end of one HMDA data collection year and the beginning of a new one. If there were issues in your 2004 data, work now to develop lending patterns that show a better picture.
- The Oklahoma City check processing office closes on January 21, 2006.
FEBRUARY
- Last chance for HMDA and CRA reports. Once you have pulled your data together, look at it with the eye of experience. Pay close attention to pricing, demographics, and locations.
- The medical information rule takes effect on April 1. Train everyone. Creditors need compliance training. Everyone should have awareness training.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 14, 12/05
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