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.
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.
June 1, 2001 is the due date for comments on the interim rules for electronic disclosures under Regulations B, E, M, Z, and DD.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 asking for comments on issues to consider in the CRA review scheduled for 2002.
You are halfway through the lending year. Review your CRA and HMDA data reports and evaluate where you stand. Compare your results with last year's at this time and identify any areas that need more effort.
Use creative training techniques, such as a daily or weekly question or test. Make it open book, like real life, but require people to write or e-mail you their answers. This kind of refresher training is easier to around vacation dates.
Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 4, 4/01
First published on 04/01/2001