COMPLIANCE CALENDAR

MARCH

• It's time to review your BSA exempt list. This is due each March. Each exemption is good for two years, but you still need to track account activity on a regular basis. Get this done on your breaks from HMDA.
• Comments are due to the FDIC on the draft guidance for payday lending. Send comments to PaydayComments@fdic.gov.
• Commentary updates to Regulation Z should be out late this month. Updates are usually published before the end of March to take effect on October 1 of the same year.
• Watch for regulatory developments. Rules on Customer Identification should be out sometime. There are still promises to "tweak" CRA. It is promised out..."sometime." And then there's the matter of a pending regulation for FCRA.

APRIL

• New Regulation W takes effect for transactions as of or after this date.
• OTS has revised its affiliate transaction rules. The new rules take effect on April 1.
• Comments on the proposed commentary changes to Regulation C are due by April 8, 2003.
• Voluntary compliance with the new version of Regulation B begins on the 15th. You have up to a year (April 15, 2004) to get in final compliance.
• April is Fair Housing Month. Schedule a fair lending assessment. Also schedule training. Not only is this a good anniversary month, the housing sales and mortgage applications usually increase in the spring.

MAY

• Before getting too deep into the lending season, evaluate your HMDA and CRA data. Find out whether your training had an effect. Look at your demographics and whether your lending matches your market. If not, it's time for a special outreach project.

JUNE

• The privacy regulation's anniversary is coming up. If you are still on your original schedule, annual notices are due out no later than this month.
• Wrap up the quarterly HMDA and CRA information. This is an opportunity to stay on top of the data quality.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 2, 3/03