COMPLIANCE CALENDAR

APRIL

• New Regulation W takes effect for transaction 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.
• Watch for regulatory developments. Rules on Customer Identification should be out very soon. The agencies are still promising to "tweak" CRA. It is promised out..."sometime." And then there's the matter of a pending regulation for FCRA.

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.
• Review all contracts with third parties to be sure they contain privacy agreements.
• Review the status of your privacy policies, practices, and agreements. Get a quick inventory done before it is time to get out your annual notices.

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. And this is your last chance to check your contracts to be sure that vendor agreements are in place by July 1.
• Wrap up the quarterly HMDA and CRA information. This is an opportunity to stay on top of the data quality.

JULY

• This is usually your quiet time. Don't count on it this year. There may be changes to RESPA's Regulation X and there will be customer identification rules to implement. Procedures for the new HMDA reporting requirements should be in place this fall. Be ready.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 4, 4/03