COMPLIANCE CALENDAR

JULY

• Work on your Customer Identification Policy. Be ready to take it to the Board in August (just in case they postpone the meeting until September.)
• While developing the CIP program, review compliance procedures for new accounts. This is a good time to make sure that you have good procedures and disclosures for Regulations CC, DD, D and E.
• Schedule training for all staff on the CIP program. Compile clippings from news sources about money laundering cases and terrorist investigations. Prepare examples of IDs typically used in your market.

AUGUST

• Pull together information for next year's budget. Keep some support tools handy, such as the FRB's agreement with Fifth Third Bank and the flood enforcement cases. Use Governor Bies' speech to the ABA National Regulatory Compliance Conference to support your budget request.
• Check application and loan forms for compliance with the changes to Regulation B. For that matter, check for compliance with all of Regulation B. Pay special attention to signatures and information gathering. Develop a work plan for anything that needs to be changed.
• Look into acquiring and placing new application forms to comply with HMDA reporting requirements. These should be available and in use before the end of the year.

SEPTEMBER

• Comments are due to the regulatory agencies by September 15, 2003 on ways to reduce regulatory burden with respect to regulations on applications and reporting, powers and activities, and international activities.
• Hold training on the Regulation B changes. Make sure your commercial lenders know about signature requirements and documentation best practices.
• Do a last minute check on CIP and Regulation B to be sure you haven't created a conflict or problem.

OCTOBER

• Oops. The Regulation B changes do not take final effect on the 15th of this month (as we erroneously reported in the last issue). They take final effect on April 15, 2004.
• The Regulation Z commentary update does take final effect this month. Use it to be sure you are using the correct Treasury securities index for HOEPA calculations.
• Customer Identification procedures must be in place before the end of this month.
• Hold training on the HMDA changes and how your institution will handle the transition to the new rules.

NOVEMBER

• It's crunch time for implementing changes to HMDA. Check your schedule and that of operations staff to be sure you have enough time to be ready.
• Pending: 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.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 7, 7/03