COMPLIANCE CALENDAR

MARCH

• Comments are due to the Federal Reserve on the Advance Notice of Proposed Rulemaking on Regulation Z rules affecting open end credit by March 28.
• Update your BSA exemption list. Remember to study the account activity.
• While working on your exemption list, review the quality of your customer risk assessments and due diligence. Be sure you meet your regulator's expectations.
• If you encountered problems preparing your HMDA LAR, start now to prevent the same problems in your 2005 data. Review procedures and schedule training.
• Watch for updates to the FRB Official Staff Commentaries, especially for Regulation Z.

APRIL

• It's Fair Housing month again. Schedule fair lending training and self-assessments for this month. Include training on collection of monitoring data and documentation requirements.
• Do a readiness assessment on the FACT Act provisions that take effect on July 1, 2005. Train staff on identity theft flags and review procedures for obtaining and using credit reports.
• Watch for other FACT Act rules if they haven't come out yet.

MAY

• Comments are due by May 4, 2005 to the agencies on their latest request for suggestions in regulatory burden. This cycle includes BSA (there must be something there!) and several safety and soundness issues including the appraisal regulations.
• Privacy's anniversary date is coming up. Be sure your annual notices go out on time.
• And while noting the privacy anniversary, schedule privacy training. This would also be a good time to brush up on CIP.
• As a customer service, consider including identity theft information in your privacy mailing.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 2, 2/05