- Customer Identification Procedures rules should be enhanced, even though the rule won't be out for a while. Give priority to procedures and training. Discuss methods for customer identification with the customer contact staff. Use the opportunity to compile information and ideas for a stronger program.
- Schedule training for collection of monitoring data under the new HMDA requirements. Make staff practice explaining the request and asking for information.
- You should begin to implement the HMDA's new collection of monitoring information from telephone applications this month so that you can report the information on all loans closed after January 1, 2003.
- 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.
- Watch for possible publication of proposals to revise CRA. It should come out..."soon." But current word is "late this year" - or even next year.
- Keep watching for final rule-making on regulatory proposals including FCRA and Regulation B monitoring data. They are still alive.
- 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 very 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.
- It's a new year and there are new adjustment triggers for HOEPA ($488) and HMDA exemption size. Be sure you have the relevant information in place.
- Get your annual training program underway. It is too early in the year to fall behind.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 13, 11/02
First published on 11/01/2002