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CALENDAR

APRIL

  • Comments on HMDA are due to the Federal Reserve Board by April 1. 2002.
  • Comments are due at FinCEN by April 15, 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.
  • 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.

MAY

  • May is electronic check month. Use the information from the U.S. Treasury's website to prepare customer information hand-outs.
  • Take an early look at your 2002 HMDA and CRA data to evaluate whether you are on-track for fair lending and CRA.
  • Review your OFAC procedures.
  • This is a good time to conduct a privacy audit. Round one of the notices is over and round two is about to begin. Make sure your institution is doing what it has promised.
  • Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 3, 3/02

    First published on 03/01/2002

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