- You should continue (or begin) implementation of HMDA's new collection of monitoring information from telephone applications so that you can report the information on loans closed after January 1, 2003.
- 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.
- 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.
- Schedule brief meetings (with holiday munchies) with tellers, CSRs, and branch managers to discuss the customer identification program. Get their version of how identification procedures work - or should work.
- 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.
- Adjust your HOEPA audit measures to reflect $488, the new trigger for fees and finance charges for loans in 2003.
- The year isn't quite over yet. Stay alert for some last minute meetings at the FRB. They still have time to get out final rule-making on regulatory proposals including FCRA and Regulation B monitoring data. In fact, they have made a habit of late-year meetings for major proposals!
- Watch for possible publication of proposals to revise CRA. It should come out..."sometime."
- 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.
- HMDA preparation work begins in earnest. The year 2002 is over and you have 8 weeks to prepare and submit accurate data.
- Get your annual training program underway. It is too early in the year to fall behind.
- HMDA and CRA data filings are due at the end of the month.
- As soon as you finish your HMDA reports, work on the BSA exemptions. Updates and changes are due in March.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 14, 12/02
First published on 12/01/2002