- Schedule time this month to review all the contracts the bank has with third parties. Look for elements relating to privacy and liability for compliance. Make sure those contracts protect the bank.
- Deliver privacy training this month or very soon. All bank staff needs to know the general principles of the new privacy law. They also need to know enough about the bank's policy and information practices to answer customer questions. Include information about the bank's information security program.
- Get those HMDA LARs and CRA data reports in!
- Watch for an announcement from the agencies sometime this spring asking for comments on issues to consider in the CRA review scheduled for 2002.
- March 9 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation C, HMDA, to increase the information reported on the LAR.
- March 15 is the date by which you must re-certify Phase II exemptions that are two years old. Make sure that this date becomes part of your data reporting calendar.
- March 16 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation Z to strengthen HOEPA protections and limit predatory lending.
- Privacy notices should be ready to go to the printer by the end of this month. Use March 31, 2001 as a date to aim for.
- CRA in the Sunshine takes effect on April 1, 2001. Only April Fools will miss this! Check the technical rules for disclosure and be sure you are ready.
- Privacy notices should be printed this month so that they can be mailed in April or early May.
- The Federal Reserve Board is holding a research conference this month on "Changing Financial Markets and Community Development."
- April is Fair Housing Month. Schedule fair lending training. Emphasize that excellent service is critical to fair lending - and succeeding as a bank.
- While training for fair lending, include a discussion about predatory lending. This is an opportunity to sensitize bank staff to the issue. It is also an opportunity to collect ideas from bank staff on ways to inform and educate customers about predatory lending.
- If your bank is planning to share information with third parties, your opt-out system should be in place. Test it to make sure it works.
- Prepare responses to inquiries from the press. Establish a protocol for responses to press questions and circulate it to everyone in the bank.
- Privacy must be ready to go by the end of the month. Remind all bank employees about privacy and questions they may get from consumers - and news reporters - this month.
Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 1, 2/01
First published on 02/01/2001