COMPLIANCE CALENDAR

NOVEMBER

• Review any errors in HMDA reporting and use these for specific training on information collection.
• This is a good time to check up on information security. Be sure that all systems are in place and effective before the holiday frauds begin.
• Remember the annual requirements for BSA training. Since the CIP anniversary has just passed, this is a good time to schedule refresher training on BSA.

DECEMBER

• Comments are due by December 16 on the Federal Reserve's second advance notice of rulemaking regarding the open end rules of Regulation Z.
• It is compliance recognition time. Find positive things to say and give recognition where staff has done well. The absence of violations should be positively noticed. Also give recognition to anyone who found a problem - and thus prevented more damage.
• Start the HMDA reporting process. Also take a look at your data. Compare 2005 information to 2004. Look at both in the context of issues raised when the 2004 data was released.
• It is not too soon to think about the coming medical information rule. Policies, procedures and training, should all be in place before next March. Happy holidays!
• And while thinking about the medical information rule, think about the rest of the FACT Act compliance. December is FACT Act anniversary month and good time to do audits and take stock of the program.

JANUARY, 2006

• For the past several years, new compliance rules and issues have driven your job. Take some time at the beginning of this new year to review your program and set your own agenda. Focus attention where it is needed most.
• This months marks the end of one HMDA data collection year and the beginning of a new one. If there were issues in your 2004 data, work now to develop lending patterns that show a better picture.
• The Oklahoma City check processing office closes on January 21, 2006.