This is a good time to review compliance with regulations, such as Flood Hazard and the appraisal rules. Make sure everything is ship-shape for the new year.
The quality check on the accuracy of the HMDA-LAR and the CRA data reports should be well underway.
Check around your bank to be sure that everyone is using current OFAC lists. Do this often.
While others are off skiing, review your closed-end loans - especially balloon loans - to see whether they fall within the new HOEPA triggers.
Schedule a training update for lenders on predatory lending and new HOEPA disclosure requirements.
Comments to the Federal Reserve Board on proposed revisions to the Official Staff Commentary to Regulation Z by February 1.
This is your last chance for the CRA data reports and the HMDA-LAR. Be ready or have lots of spare time.
Review the status of your exempt customers for CTR reporting. Updates are due next month.
Watch for possible publication of proposals to revise CRA. It is early days yet, but it could happen.
We may also see final rule-making on several other regulatory proposals including FCRA and Regulation B monitoring data.
After you finish your CRA and HMDA data reporting, be sure to get in your BSA exempt list by the middle of the month.
March is a good month for BSA and OFAC training. Review the procedures and make sure everyone knows what to do with a suspicious customer or one who is on the OFAC list.
April is Fair Housing Month. Schedule training on fair lending. Be sure to discuss predatory lending and CRA to tie them all together.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 16, 1/02
First published on 01/01/2002