Phase I of the Digital Signature Act took effect on October 1. Accomplish two things at once by making electronic disclosures and electronic procedures part of your privacy review and program.Update your OFAC list!
Also plan to dedicate some time to Fair Credit Reporting. Work with the commercial lending department to establish whatever is needed - procedures, forms - to ensure that the lenders obtain the permission of each individual for whom they need to obtain and use a credit report.
Do a BSA audit and check how your exemption process is working. Make sure everyone is following the new procedure and using the correct forms.
It's traditional to do Truth in Lending training this month. All new provisions from the Commentary updates take effect this month.
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.
Keep working with your privacy task force to write policies and procedures for privacy. Get as much done as possible before Thanksgiving - before you enter the holiday down time.
Watch for a proposal from the Federal Reserve to update and revise Regulation C, Home Mortgage Disclosures. Get a head start on compiling opinions and information for a comment letter.
Try to spend some time with senior management - you may have to take someone to lunch - to find out the plans or thinking for new products, such as insurance. In a user-friendly way, deliver the message that you need to be part of the planning team to be sure that the compliance requirements are taken into account.
Remember your annual compliance recognition program. Give something to people that have done a particularly good job.
While everyone else is at the office holiday party, take stock of where your privacy efforts stand. Review accomplishments and compare them to your calendar. Any shortfall should be made up next month.
Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 12, 11/00
First published on 11/01/2000