Compliance Calendar

JUNE
Now that we know what needs to be done, assemble a privacy implementation team. Get representation throughout the bank. Follow the Y2K blueprint and involve all bank functions.

During June and July, conduct a privacy inventory. Find out who has information about customers, how it comes into the bank, how it is stored, and who uses customer information. Get everything - from signature cards to the mainframe.

The new process for Tier II exemptions for your CTR filings takes final effect in July. If you haven't already done so, this is your last chance to get rid of the old exemption list. Remember to tell all bank staff to no longer use the old list. As of July 1, you must use the new exemption procedure - or nothing.

Comments on the proposed Q&As for CRA are due to the agencies by June 27, 2000.

Oops! It's the end of another HMDA quarter. Compile that data!

JULY
July 1, 2000 - This is it for implementing the new exemption procedure.Comments on the Federal Reserve Board's proposal to amend Regulation Z are due no later than July 18, 2000.

Comments on the CRA Sunshine proposal are due July 21, 2000.Pull together information to support your budget proposal for next year. Be sure to allot funds for training - for yourself. This is going to be a big year for new developments.

AUGUST

Nominations for the Consumer Advisory Council are due to the Federal Reserve Board no later than August 1, 2000.

Using your privacy inventory, identify the information protections and procedures that must be put into place. Work with your privacy task force to write policies and procedures for privacy.

It's budget time. Schedule both time and money for compliance education, especially seminars on privacy, fair lending, and CRA!

Update your OFAC list. Do this often!

SEPTEMBER
Train all front line staff on privacy. Include discussion and examples of what to say - and what not to say - to consumers. Present privacy as a customer service issue.

OCTOBER
It's traditional to do Truth in Lending training this month. All new provisions from the Commentary updates take effect this month.

NOVEMBER
Beginning November 13, 2000, compliance with the new privacy regulation is voluntary. It becomes mandatory on July 1, 2001. This is one of those regulations that makes sense to implement as soon as possible.

Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 6, 6/00