October 1,1995 was to have been a big day in the world of criminal referrals and currency transaction reporting. Simplified forms and reporting procedures were to have taken effect that day. The new Currency Transaction Report form (Form 4789) has been available for several months. You should have begun using it on October 1, 1995. It's use will not be mandatory for magnetic filing until January 1996. Hopefully, by that time, the Suspicious Activity Report will be in final form. The simplified procedures and new forms for reporting suspicious transactions should be out any day. Watch for their release.
New Truth in Lending rules on high cost mortgages took effect on October 1. Also, the 1995 revisions to the Official Staff Commentary took effect that same day. Pay special attention to the revisions affecting finance charge calculations! That includes courier fees and some or all of the price of flood hazard area searches.
The federal banking regulatory agencies have released proposed regulations to implement the National Flood Insurance Act. The proposal presents regulatory solutions to some "gray" areas. The agencies will want to hear from you to help them develop a final regulation.
Fact: Compliance isn't easy. The Federal Reserve System examiners found compliance violations in over 97% of the banks they examined in 1994.
Consumer allegations of discrimination are beginning to proliferate. Stories in the news may be encouraging people to think that a denial is discrimination. If your bank receives a complaint, treat the complaint or inquiry as a priority. Investigate the complaint, be sure you understand what caused the complaint, and respond to the customer quickly. Finally, keep records of your investigation and response.
Copyright © 1995 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 1, 11/95
First published on 11/01/1995