Compliance Calendar

JULY
July 1, 2000 - This is it for implementing the new exemption procedure.

Keep working on your privacy inventory. Find out who has information about customers, how it comes into the bank, how it is stored, and who uses customer information. Get everything - from signature cards to the mainframe.

Comments on the Federal Reserve Board's proposal to amend Regulation Z are due no later than July 18, 2000.

Comments on the CRA Sunshine proposal are due July 21, 2000.

Pull together information to support your budget proposal for next year. Be sure to allot funds for training - for yourself. This is going to be a big year for new developments.

AUGUST
Nominations for the Consumer Advisory Council are due to the Federal Reserve Board no later than August 1, 2000.

Using your privacy inventory, identify the information protections and procedures that must be put into place. Work with your privacy task force to write policies and procedures for privacy.

It's budget time. Schedule both time and money for compliance education, especially seminars on privacy, fair lending, and CRA!

Update your OFAC list. Do this often!

SEPTEMBER
Train all front line staff on privacy. Include discussion and examples of what to say - and what not to say - to consumers. Present privacy as a customer service issue.

OCTOBER
It's traditional to do Truth in Lending training this month. All new provisions from the Commentary updates take effect this month.

NOVEMBER
Beginning November 13, 2000, compliance with the new privacy regulation is voluntary. It becomes mandatory on July 1, 2001. This is one of those regulations that makes sense to implement as soon as possible.

Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 7, 7/00