Regardless, if you think about it logically, the annual test would be due by 7/29/12 anyway since the drop-dead date to register was 7/29/11. In following that logic, if your bank completed all of the necessary registrations prior to 7/29/11, your annual test should be/have been done by 12 months following the date of your last registration.
In any event your 1st annual test should be completed by 12 months following the mandatory compliance date (7/29).
ETA: FWIW, I did mine in December, and I know other banks did theirs in January. It was built into the audit schedule to coincide with the completion of the annual renewals.
Last edited by Dani York; 05/23/12 04:55 PM.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.