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.
Last edited by Dani York; 05/23/12 04:55 PM.
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.
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.