- Consumer report information disposal rules took 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.
- Check the last time you presented flood hazard training. If it was "a while ago" schedule more training soon.
- Make flood training realistic. Audit some loan files and review flood hazard insurance tracking. Bring up any findings - enhanced by estimated penalties - in 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.
- Check the status of regulatory publications from the Federal Reserve. Several rules, including Regulation E, are in process and may be published in late summer or early fall.
- OFAC reports on blocked or frozen assets are due on September 30. Check your accounts and prepare OFAC reports, if you have anything to report.
- September is a good month for Truth in Lending training. While there are no significant changes going into effect on October 1, you might as well stay on schedule with training.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 8, 7/05
First published on 07/01/2005