COMPLIANCE CALENDAR

JANUARY

• Update high cost mortgage calculation forms to reflect the calculation base for 2005. The new cost is $510.
• Annual reports on insiders' indebtedness are due by the end of the month. Start collecting them now.
• Comments on the OTS proposal to revise CRA regulations are due by January 24.
• Start off the year with a gift for tellers to help them with Regulation CC. Provide them with cards that show local area routing numbers. Be sure that you have any new local routing numbers that result from the FRB's consolidations.
• Look over your training calendar for the year. Schedule all needed training and don't let anyone cut class.
• Review the process for placing and tracking identity theft and active duty alerts. Get an early read on how it is working and whether any issues need to be addressed.
• Round up the HMDA data from last year and start scrubbing. Look for any systemic errors that should be dealt with by the unit that made the error. Get the system and last year's data fixed the most efficient way.

FEBRUARY

• Get the HMDA data in by the end of the month - or sooner. Be sure to do a quality and edit check before sending in your data.
• If HMDA is under control, review your BSA exempt list. This should be updated next month. Be sure you have time to give appropriate attention to account activity of exempt customers.
• Also pull together a team to conduct an information security assessment. Look at requirements under BSA, G-L-B, the FACT Act, and any other requirements you can think of.

MARCH

• Comments are due to the Federal Reserve on the Advance Notice of Proposed Rulemaking on Regulation Z rules affecting open end credit by March 28.
• Update your BSA exemption list. Remember to study the account activity.
• Watch for updates to the FRB Official Staff Commentaries, especially for Regulation Z.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 16, 1/05