After surviving the planning and execution of an archery party for my nine-year-old son and about 18 of his closest friends, I came to realize the end of the year was hurtling toward me faster than I could keep up with. Packed in the fourth quarter each year are occasions such as his birthday, Halloween, Thanksgiving, and Christmas — all within approximately 75 days! No wonder I may feel a little more “high strung” toward the end of the year!
During this time of year, I live by lifelines including lists, sticky notes, and a master family calendar on the door to my garage — without these, I could not stay on track.
As compliance professionals, we continually live with deadlines for reports, audits, examinations, new products, new systems and disclosure changes, and the list goes on. So as we are all dealing with a fast-ending 2018, here are a few things to make certain that you have crossed off your to-do list before the end of the year.
- Officer approvals. Has your board approved (and documented) the named bank officers and their relevant titles?
- Policy/program approvals. Has your board approved (and documented) your most recent policies and programs?
- Training. Has everyone (including the board) completed the required annual training for your institution, and is it documented?
- Audits. Have all your internal and external monitoring/audits been completed for the current year/cycle? If not, have you documented why there may be a discrepancy between your institution’s written compliance, or audit risk assessment, and the completed work for the current year/cycle?
- Red Flags annual report requirement. Have you provided a report on compliance with the Red Flags rules to the board, committee of the board, or member of senior management designated as responsible for oversight?
- SAFE Act. Have you started working on the annual renewal registration (November 1 – December 31) as applicable? In addition, have you scheduled/performed the required annual independent testing for compliance with the Act to be performed by bank personnel or an outside party?
- Regulation O. If you are a bank, have you, through an annual survey, identified all insiders of your bank and insiders of your bank’s affiliates, with records of all extensions of credit to insiders of the affiliates? Do you need a board resolution to name your Regulation O executive officers for the coming year?
- ACH audit. If required, have you completed or scheduled for completion before year-end the annual ACH audit to comply with the NACHA rules?
If you find yourself not having time to complete some of these tasks on your to-do list, just give us a call. We would be happy to take the burden from you. Now you can, hopefully, relax and enjoy all the upcoming holidays.