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.
Compliance with rules on sale of insurance to consumers has been postponed to October 1, 2001. Take a deep breath.Privacy notices should be printed this month so that they can be mailed in April or early May.
If you haven't yet, schedule privacy training. All bank staff needs to know the general principles of the new privacy law, and enough about the bank's policy and information practices to answer customer questions. Your front line should be selling your privacy program.
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. Also show the connection between fair lending and privacy.
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 notices are landing. Refresh your customer contact staff so that they can answer customer questions. There are likely to be a lot of questions.
Comments on the Interim Rules for electronic disclosures are due by June 1, 2001.
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.
Watch for an announcement from the agencies sometime this spring asking for comments on issues to consider in the CRA review scheduled for 2002.
Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 3, 4/01
First published on 04/01/2001