Compliance Calendar

JUNE

• If your bank is planning to share information with third parties, test your opt-out system to make sure it works.
• Prepare responses to inquiries from the press. Establish a protocol for responses to press questions and circulate it to everyone in the bank.
• Privacy notices are landing. Refresh your customer contact staff so that they can answer customer questions. Have the customer contact personnel practice answering "customer" questions.
• June 1, 2001 is the due date for comments on the interim rules for electronic disclosures under Regulations B, E, M, Z, and DD.
• June 8, 2001 is the due date for comments on interstate deposit production.
• Watch for an announcement from the agencies asking for comments on issues to consider in the CRA review scheduled for 2002.

JULY

• You are halfway through the lending year. Review your CRA and HMDA data reports and evaluate where you stand. Compare your results with last year's at this time and identify any areas that need more effort.
• Use creative training techniques, such as a daily or weekly question or test. Make it open book, like real life, but require people to write or e-mail you their answers. This kind of refresher training is easier to work around vacation dates.

AUGUST

• Review your CRA and HMDA data to evaluate your CRA performance. If things need improving, you are running out of time.
• This is also a good time to do a quality test on your HMDA LAR. If errors are emerging, you have time to fix them well before the HMDA crunch.
• Review materials and tools you use for training. Make sure they are current. If not, revise or replace them.

SEPTEMBER

• Rules on the sale of insurance to consumers take effect next month. Schedule training on all non-deposit products for staff this month.

OCTOBER

• Rules on sale of insurance to consumers takes effect on October 1, 2001. Be ready.
• ATM notices describing non-customer fees must be in place by October 1, 2001 - unless your equipment is technologically obsolete. Also make sure that initial disclosures warn customers about third party ATM fees.

Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 5, 5/01