Compliance Calendar

December

• Comments are due to the bank regulatory agencies on the FCRA proposal. Get your comments in by December 4, 2000.
• Comments are due by December 17, 2000 to the FDIC on its predatory lending paper.
• Remember your annual compliance recognition program. Give something to people that have done a particularly good job.
• While everyone else is at the office holiday party, take stock of where your privacy efforts stand. Review accomplishments and compare them to your calendar. Any shortfall should be made up next month.
• If you haven't done so already, review adverse action notices. Look for complete and accurate reasons. Also look make sure that FCRA notices went to all applicants.
• If you have a quiet moment and haven't done so yet, check out our website at www.bankersonline.com. It is a wonderful place to get questions answered and find authority for your briefings. Plus, as a subscriber, you can get all the articles from back issues of the Compliance Action newsletter.

January

• The HMDA count down begins. So does the countdown for CRA data. Get those final entries in and begin your final quality check of the data.
• While working on your LAR, give a good look at your process for compiling and entering information. Then consider how you would compile the additional information the FRB's proposal would ask for. Use this in your comment letter.
• Work on a comment letter for the FRB's proposal to revise Regulation C and the beloved HMDA LAR. Describe your process compiling information and for preparing the LAR. Give a clear summary statement of what would be changed (burden added) to comply with the proposal.
• Since you probably lost momentum for privacy during the holidays, it is time to get things moving again. Review and revise your targets.

February

• Get those HMDA LARs in!
• Get the CRA data reports in!

March

• March 15 is the date by which you must re-certify Phase II exemptions that are two years old. Make sure that this date becomes part of your data reporting calendar.

April

• The Federal Reserve Board is holding a research conference this month on "Changing Financial Markets and Community Development."

Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 14, 12/00