Question & Answer

Question: When will Examiners look at our privacy efforts? Will they be doing privacy examinations before July 1, 2001?

Answer: There are two answers to your question: yes and no. Prior to July 1, 2001, there probably won't be privacy examinations. The procedures are being developed now. This is a process that doesn't take place overnight. Then, after the exam procedures are adopted, there will be training for examiners. It's going to be July 1, 2001 or pretty close to it before the agencies are ready.

In the meantime, however, that does not mean that your privacy efforts won't be looked at. Financial institutions can expect a privacy readiness check-up as a part of examinations scheduled between now and the July 1 effective date. This will be much like the Y2K audits. They will assess whether you are where you should be in order to be ready to comply on July 1, 2001.

In addition, some of the agencies will be sending information requests or calling institutions that do not have exams scheduled during that time period. So, regardless of your examination schedule, be ready to tell your regulator where you stand.

Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 13, 11/00