CALENDAR

MAY

• May is electronic check month. Use the information from the U.S. Treasury's website to prepare customer information hand-outs.
• Take an early look at your 2002 HMDA and CRA data to evaluate whether you are on-track for fair lending and CRA.
• Review your OFAC procedures. Also check the latest OFAC list. Make sure you check the new list against existing accounts.
• Watch for possible publication of proposals to revise CRA. It should come out..."soon."
• We may also see final rule-making on several other regulatory proposals including FCRA and Regulation B monitoring data.
• This is a good time to conduct a privacy audit. Round one of the notices is over and round two is underway. Make sure your institution is doing what it has promised.
• Use the government's free brochure that explains privacy notices and privacy rights. This should help to minimize customer confusion and frazzled phone calls.

JUNE

• June 30th is the annual deadline to file a report of Foreign Bank and Financial Accounts (FBAR) with the U.S. Department of Treasury. Earlier is OK. Forms are available on FinCEN's website.
• This is your last chance to revise contracts with vendors to ensure that your service agreements are in compliance with the privacy regulation's requirements. See section __.18(c) in case anyone has questions.
• Use the checklist for Unfair and Deceptive Trade Practices to review your institution's practices. Schedule a training meeting to discuss UDTPs with staff.
• Review your accomplishments so far this year. Use the quiet time of early summer to plan your schedule for the rest of the year.
• Use this time to review your compliance training calendar. Set the agenda for the rest of the year and give people plenty of advance notice.

JULY

• Contracts with all service providers should now contain clauses that ensure the privacy of your customers' information.
• If you think you don't make HOEPA loans (12 CFR 226.32) this is a good time to make sure. Test balloon loans and all dwelling-secured loans with high rates and/or fees against the new HOEPA triggers.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 5, 5/02