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  • HMDA and CRA data filings are due at the end of the month. And there are only four short weeks in February. Get cracking!
  • As soon as you finish your HMDA reports, work on the BSA exemptions. Updates and changes are due in March.
  • Customer Identification Programs are or will soon be a priority. Get the team to work!
  • Watch for regulatory developments. Rules on Customer Identification should be out sometime. There are still promises to "tweak" CRA. It is promised out..."sometime."


  • 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.
  • Comments are due to the FDIC on the draft guidance for payday lending. Send comments to:
  • Commentary updates to Regulation Z should be out late this month. Updates are usually published before the end of March to take effect on October 1 of the same year.


  • 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.


  • Before getting too deep into the lending season, evaluate your HMDA and CRA data. Look at your demographics and whether your
    lending matches your market. If not, it's time for a special outreach project.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 1, 2/03

First published on 02/01/2003

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