COMPLIANCE CALENDAR

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

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

Gear up for implementation of final rules on Customer Information Procedures under the USA PATRIOT Act. Use the proposal to develop your procedures.

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.

Set aside time to comment on HUD's proposal to revise the Good Faith Estimate form and procedure. Your vote and your information really count!

Check with your lawyers and/or your state Attorney General Office to find out more about state laws that may affect customer privacy.

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 Customer Information Procedures. Include discussions of Suspicious Activity Reports and the OFAC list.

Customer Information Procedures should go to your board of directors for approval this month or early next month.

OCTOBER
Customer Information Procedure rules should take effect on October 24, 2002. Make sure you 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."It is time to do a quality check on HMDA data. Also check CRA data if you are a CRA reporter.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 11, 8/02