This really should be a full blown program with someone responsible for making sure that all aspects of it work and work together. HR has a piece, facilities has a piece, business units have a piece, training has a piece, etc.
_________________________ Kathleen O. Blanchard, CRCM "Kaybee" HMDA/CRA Training/Consulting/Mapping The HMDA Academy www.kaybeescomplianceinsights.com