New HOEPA rules and triggers took effect on October 1. Make sure you aren't making any. Also include regular HOEPA audits into your annual audit schedule as a preventive measure.
Train all staff on Customer Information Procedures. Include discussions of Suspicious Activity Reports and the OFAC list.Customer Information Procedure rules should take effect on October 24, 2002. Make sure you have procedures in place and people fully trained.
Comments to HUD on the proposed "simplification" of the Good Faith Estimate are due by October 28. Don't miss this date! Financial institutions MUST tell their side of the story.
Watch for possible publication of proposals to revise CRA. It should come out..."soon." But word is beginning to be "late this year."Keep watching for final rule-making on regulatory proposals including FCRA and Regulation B monitoring data.
Schedule training for collection of monitoring data under the new HMDA requirements. Make staff practice explaining the request and asking for information.
It is time to do a quality check on HMDA data. Also check CRA data if you are a CRA reporter. Use the information to do a quick check on your lending programs and brief management on where you stand for CRA and fair lending.
Schedule brief meetings (with coffee and donuts) with tellers, CSRs, and branch managers to discuss the customer identification program. Get their version of how identification procedures work - or should work.
Adjust your HOEPA audit measures to reflect $488, the new trigger for fees and finance charges.The year is almost over and it has been a busy one! Sit back and count the ways in which your glass is half full.
Before going to holiday parties, 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.
This is your last chance to train loan officers on procedures for collecting monitoring data for telephone applications. Training can be quick and painless, but make sure they practice explaining why they are asking for the information.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 12, 10/02
First published on 10/01/2002