COMPLIANCE CALENDAR

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. Emphasize finance charges imposed by third parties and rescission.

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

Check around your bank to be sure that everyone is using current OFAC lists. Make this a regular practice.

Be sure to ask for the compliance tools you need in your budget request. Categorize any conference or seminar as training so that management knows you won't spend your time on the golf course.

OCTOBER
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.

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

The October 1, 2001 effective date for e-sign revisions to Regulations B, E, M, Z, and DD has been deferred. No new compliance date is in effect, but watch for possible revisions to the rules to add flexibility for institutions.

Comments on the CRA Advance Notice of Proposed Rulemaking are due to the agencies by October 17, 2001. Be sure to comment.

NOVEMBER
Review your training calendar for next year. Make sure you have all the regulations covered. Also make sure that everyone's training is current.

Look for a way to reward compliance performance. Let people know their efforts make a difference.

Gear up for HMDA and CRA data collection. The agencies are expecting accurate reports for this year.

DECEMBER
This may be the slowest things have been in several years. Try to find time to assess where you are and where you are going. Map out a plan for next year.

Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 11, 9/01