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  • Watch for updates to the FRB Official Staff Commentaries, especially for Regulation Z.
  • It's Fair Housing month again. Schedule fair lending training and self-assessments for this month. Include training on collection of monitoring data and documentation requirements.
  • Update your check routing information for tellers and operations. New routing patterns take effect on April 16 and April 23 as the Fed closes down the Detroit and Houston check processing centers.
  • Do a readiness assessment on the FACT Act provisions that take effect on July 1, 2005. Train staff on identity theft flags and review procedures for obtaining and using credit reports.
  • Watch for other FACT Act rules if they haven't come out yet.


  • Comments are due by May 4, 2005 to the agencies on their latest request for suggestions in regulatory burden. This cycle includes BSA (there must be something there!) and several safety and soundness issues including the appraisal regulations.
  • Comments on the agencies' CRA proposal are due by May 10, 2005. This is your chance to be heard on issues concerning community development and rural credit needs, as well as the definition of a small bank.
  • Privacy's anniversary date is coming up. Be sure your annual notices go out on time.
  • And while noting the privacy anniversary, schedule privacy training. This would also be a good time to brush up on CIP.
  • As a customer service, consider including identity theft information in your privacy mailing.


  • Review the year so far and plan ahead. Update your training calendar and audit schedule to get in what must be done before the end of the year.
  • Work with your IT staff to place website links to important consumer information such as the identity theft information at the FTC.
  • Plan some time for personal R&R. It has been a challenging year.


  • This is often a slow month. Use it to catch up. Also start pulling together material for your budget.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 4, 4/05

First published on 04/01/2005

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