Compliance Calendar

MARCH

• Provisions of the Patriot Act are taking effect and new rules will be coming out. Watch www.BankersOnline.com for developments. The provisions that make changes to BSA and OFAC will be a priority for everyone - including your regulator.
• 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.
• 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.

APRIL

• Comments on HMDA are due to the Federal Reserve Board by April 1, 2002.
• Comments are due at FinCEN by early April, 2002 on the proposed Information Sharing regulations.
• Comments are due at FinCEN by April 22, 2002 on the proposed Designation of Exempt Person Form.
• 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.
• Also do a HOEPA audit. Look at your higher cost loans and balloon loans to see if they set off the new HOEPA triggers.

MAY

• Take an early look at your 2002 HMDA and CRA data to evaluate whether you are on-track for fair lending and CRA.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 2, 3/02