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Compliance Calendar

JANUARY

  • By now, you should have decided how to respond to the lapse in NFIP. Turn this crisis into a training opportunity. Stress safety and soundness concerns on uninsured property.
  • Comments on the proposed revisions to the Truth in Lending Official Staff Commentary are due to the Federal Reserve Board by January 27, 2003.
  • It's a new year and there are new adjustment triggers for HOEPA ($488). The HMDA exemption size remains unchanged at $32 million. 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 for 2002. You also have to begin collecting monitoring information for telephone applications.
  • Get your annual training program underway. It is too early in the year to fall behind.
  • Customer Identification Programs are or will soon be a priority. Get the team to work!
  • And while watching for possible regulatory publications, don't forget about CRA. A proposal to tweak the current regulation should come out..."sometime."

FEBRUARY

  • 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.

MARCH

  • It's time to review your BSA exempt list. This is due each March. Each exemption is good for two years, but you still need to track account activity. Get this done on your breaks from HMDA.

APRIL

  • OTS has revised its affiliate transaction rules. The new rules take effect on April 1.
  • April is Fair Housing Month. Schedule a fair lending assessment. Also schedule training. Not only is this a good anniversary month, the housing sales and mortgage applications usually increase in the spring.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 16, 12/02

First published on 12/01/2002

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