Data and Reports

JULY
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 work around vacation dates.Check around your bank to be sure that everyone is using current OFAC lists. There have been a lot of changes to the OFAC list recently.

AUGUST
Comments on the proposed Regulation W, dealing with transactions between a bank and its affiliates, are due to the Federal Reserve by August 15, 2001.

Comments on the OCC's notice of proposed rulemaking for electronic banking are due by August 31, 2001.

Review your CRA and HMDA data to evaluate your CRA performance. If things need improving, you are running out of time.

This is also a good time to do a quality test on your HMDA LAR. If errors are emerging, you have time to fix them well before the HMDA crunch.

Review materials and tools you use for training. Make sure they are current. If not, revise or replace them.

SEPTEMBER
Rules on the sale of insurance to consumers take effect next month. Schedule training on all non-deposit products for staff this month.

This is also a good month to train on Truth in Lending.

Check your ATMs to be sure the notices about non-customer fees are posted.

OCTOBER
Rules on sale of insurance to consumers takes effect on October 1, 2001. Be ready.

Comments on the CRA Advance Notice of Proposed Rulemaking will be due to the agencies this month.

ATM notices describing non-customer fees must be in place by October 1, 2001 - unless your equipment is technologically obsolete.

Also make sure that initial disclosures warn customers about third party ATM fees.

Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 8, 8/01