Comments should have been 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.
Provisions of the Patriot Act are taking effect. Watch www.BankersOnline.com for developments. The provisions that make changes to BSA and OFAC will be a priority for everyone - including your regulator.
Review the status of your exempt customers for CTR reporting. Updates are due next month.
While others are off skiing, review your closed-end loans - especially balloon loans - to see whether they fall within the new HOEPA triggers.
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.
Comments on the FTC's proposed changes to the Telemarketing Sales Rule, including the central "do not call" registry, are due to the FTC by March 29, 2002.
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.
Comments on HMDA are due to the Federal Reserve Board by April 1, 2002.
April is Fair Housing Month. Schedule training on fair lending. Be sure to discuss predatory lending and CRA to tie them all together.
Schedule a training update for lenders on predatory lending and new HOEPA disclosure requirements.
After training, schedule a fair lending audit. Use the fair lending examination procedures to set your audit scope.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 1, 2/02
First published on 02/01/2002