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  • The new CRA rule affecting intermediate small banks took effect on September 1, 2005. If your institution falls into this size range, look carefully at the revised regulation and then revise your CRA program.
  • One-free-credit report per year is now available all across the country. Be prepared for customer questions and complaints.
  • 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.
  • In preparation for commenting to the FDIC on deposit insurance for stored value cards, compile information on the number and nature of stored value cards that your institution may offer or handle. Consider the proposal's implications in the context of what information you do or do not have about the card holders.


  • Comments on the FRB's proposed changes to Regulation E affecting ATM operators are due on October 7, 2005.
  • Comments on the FDIC's stored value deposit card insurance proposal are due this month. Get your comments in.
  • Anniversary dates are always fun. There are several in October, including ECOA and CIP. This is a good time to schedule training on obtaining, storing and using customer information, including information that may be prohibited by Regulation B.
  • Use your CIP and BSA audits to evaluate and redesign your BSA risk assessment program.
  • Dress up as your favorite regulation for the Halloween party.


  • Review any errors in HMDA reporting and use these for specific training on information collection.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 10, 9/05

First published on 09/01/2005

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