- 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.
- But first, schedule time on June 30th to download the new BSA examination procedures. They say they'll be posted sometime that day.
- Consumer report information disposal rules take effect on the 1st. Check your information security procedures.
- This is often a slow month. Use it to catch up. Also start pulling together material for your budget. Be sure to include funds for your own training.
- If you use credit bureau reports for pre-screening, check your notices and procedures to be ready for the new rules which take effect on August 1, 2005.
- FACT Act prescreening opt out notice rules take effect August 1, 2005.
- Schedule time for one of the federal agencies' BSA exam procedure briefings. National telephone conferences will be held on August 2-4. These will be followed by regional meetings in 5 cities from August 15 - 24th. Visit the FRB's website for more information.
- HMDA data will be released some time this fall. Get ready. We already know what groups may be looking at. Do your own analysis first. Look at 2004 and the first six months of 2005.
- Schedule HMDA training. Design a training program that is directed at any weak points you have identified.
- Start watching for action on the CRA proposal. There might be something final by the end of the summer.
- OFAC reports on blocked or frozen assets are due next month. Check your accounts and prepare OFAC reports, if you have anything to report.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 7, 6/05
First published on 06/01/2005