COMPLIANCE CALENDAR

JANUARY

• The HMDA reporting threshold is now $35 million in assets. If you are a very small institution, check your asset size.
• Comments on the proposed changes to the CRA Q&As are due to your regulatory agency by January 9, 2006.
• Get the Annual Reports on Indebtedness of Executive Officers and Principal Shareholders in before the end of the month.
• For the past several years, new compliance rules and issues have driven your job. Take some time at the beginning of this new year to review your program and set your own agenda. Focus attention where it is needed most.
• This months marks the end of one HMDA data collection year and the beginning of a new one. If there were issues in your 2004 data, work now to develop lending patterns that show a better picture.
• The Oklahoma City check processing office closes on January 21, 2006.

FEBRUARY

• Comments are due late this month on the agencies' proposed guidance on nontraditional mortgage products.
• Last chance for HMDA and CRA reports. Once you have pulled your data together, look at it with the eye of experience. Pay close attention to pricing, demographics, and locations.
• The medical information rule takes effect on April 1. Make certain that your policies and procedures have been updated to incorporate this rule. Train everyone. Creditors need compliance training. Everyone should have awareness training.

MARCH

• When you have finished the HMDA and CRA reports, it is time to tackle the BSA exempt list. Update your information and review compliance for exempt customers.
• While working on the exemption list, set up or update your list of customers that are MSBs. Set up a system so that you can show examiners that you have verified their filing compliance.
• Amendments to Appendix A of Regulation CC take effect on March 31. Be ready for the new routing symbols.

APRIL

• The medical information rules take effect on April 1. Be ready.
• April is Fair Housing month. Schedule fair lending training. Also take a look at your HMDA LAR data for 2005 and consider what issues could be raised.

Copyright © 2006 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 16, 1/06