Compliance Calendar

JULY

• Section 312(b)(2) became effective on July 23, 2002. Be sure to 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. Comments on the proposal are due by the end of August.
• 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. 9, 7/02