Compliance Calendar

JULY
Comments are due to OFAC on July 19, 2002 regarding the proposal to make certain enforcement information public.Section 312(b)(2) takes effect on July 23, 2002. Be ready - and include existing accounts.

Contracts with all service providers should now contain clauses that ensure the privacy of your customers' information.

If you are regulated by FDIC, revise your adverse action notices to reflect the new address for consumer complaints and inquiries.

If you haven't done so yet, schedule and conduct a privacy audit. Make sure your institution is doing what it has promised.

If you think you don't make HOEPA loans (12 CFR 226.32) this is a good time to make sure. Test balloon loans and all dwelling-secured loans with high rates and/or fees against the new HOEPA triggers.

Check with those responsible for OFAC compliance. Make sure they are using the latest OFAC list. Make sure that new names on the list are checked against existing accounts.

AUGUST
Watch for final rule-making on regulatory proposals including FCRA and Regulation B monitoring data.

Gear up for implementation of final rules on due diligence (know your customer) under the USA PATRIOT Act.

Stock up on the government's free brochure that explains privacy notices and privacy rights. This should help to minimize customer confusion and frazzled phone calls.

SEPTEMBER
The annual reports on blocked or frozen funds are due to OFAC.

Set aside some time on September 11 to think about heroes - many of whom are moderate-income public servants.

Schedule training for all staff on Enhanced Due Diligence.

OCTOBER
Rules on enhanced due diligence take effect on October 24, 2002. You should have procedures in place and people fully trained.

Watch for possible publication of proposals to revise CRA. It should come out..."soon." But word is beginning to be "late this year."

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 8, 7/02