COMPLIANCE CALENDAR

JANUARY, 2001

• 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 developing your privacy program during the holidays, it is time to get things moving again. Review and revise your targets.
• 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 access to all the back issues of ComplianceAction.

FEBRUARY

• Schedule time this month to review all the contracts the bank has with third parties. Look for elements relating to privacy and liability for compliance. Make sure those contracts protect the bank.
• Get those HMDA LARs and CRA data reports in!

MARCH

• March 9 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation C, HMDA, to increase the information reported on the LAR.
• 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.
• March 16 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation Z to strengthen HOEPA protections and limit predatory lending.

APRIL

• CRA in the Sunshine takes effect on April 1, 2001. Only April Fools will miss this!
• The Federal Reserve Board is holding a research conference this month on "Changing Financial Markets and Community Development."
• April is Fair Housing Month. Schedule fair lending training. Emphasize that excellent service is critical to fair lending - and succeeding as a bank.

Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 16, 1/01