To the Chief Executive Officers of All State Member Banks, Bank Holding Companies,
Edge and Agreement Corporations, and Branches and Agencies of Foreign Banks
in the Second Federal Reserve District, and Related Information Systems Service Providers:
The Federal Financial Institutions Examination Council (FFIEC) has issued guidance for financial institutions on contingency planning to mitigate risks due to the Year 2000 date change, and on responding to customer inquiries regarding the Year 2000 date change. This guidance follows previous FFIEC Year 2000 statements on project management, business risk, vendor management, corporate customers and testing. A supervisory letter on this matter (SR 98-11) is available, together with the two FFIEC statements -- one on contingency planning, and the other on customer awareness.
Contingency Planning Guidance
Year 2000 contingency planning is needed to provide assurance that an institution's mission critical functions will continue if one or more systems fail. The board of directors and senior management of a financial institution should place a high priority on developing, validating and implementing the institution's Year 2000 contingency plan. Contingency planning must take into account the impact of external systems, including those of service providers, other financial institutions, customers, business partners, and infrastructure providers such as suppliers of power and telecommunications. Contingency planning will vary depending on the size and complexity of the financial institution.
Earlier FFIEC guidance addressed contingency planning with regard to vendor management, but today's guidance more broadly covers contingency planning with respect to renovation, testing plans, the continuation of automated information systems, and, most important, the continuation of all aspects of core business processes.
The guidance outlines four phases of contingency planning. These phases are:
- Developing organizational planning guidelines for the institution to identify core business processes and prioritize business risks;
- Completing a business impact analysis on each core business process and defining and documenting Year 2000 failure scenarios;
- Preparing a contingency plan for each core process that identifies contingency options and implementation modes and establishing trigger dates to activate the contingency plan; and
- Validating the institution's contingency plans through an independent review of the feasibility of the plans and periodically testing the plans to ensure that changes in the institution's Year 2000 project plan and actual events are incorporated into the plans as appropriate.
The guidance notes that contingency plans are required only for those mission critical applications and systems where remediation, validation and implementation of renovations have not been completed.
Customer Awareness Guidance
Customers of financial institutions will look to financial institutions for assurances that the institution is taking appropriate steps to prepare for the century date change. Today's guidance on customer awareness outlines some of the components that financial institutions should consider in developing customer awareness programs as well as some of the issues that financial institutions should be prepared to discuss with customers.
Financial institutions should consider the types of customers with whom they need to communicate and develop appropriate ways of reaching their customers, such as:
- Providing informational brochures or other written disclosures in monthly or quarterly statements;
- Establishing toll-free hotlines for customer inquiries;
- Holding seminars to discuss the Year 2000 problem and actions the institution is taking to prepare for the century date change; and
- Developing Internet sites to disseminate information to customers.
In addition, financial institutions should ensure that personnel who interact regularly with customers are trained to respond appropriately to inquiries about the century date change by referring customers to appropriate explanatory materials or expert financial institution staff.
In developing customer awareness programs, financial institutions should consider some of the issues customers might be interested in discussing and effectively communicate with them about what could happen and what they should do if problems arise. The FFIEC is developing a consumer brochure that provides information to consumers about the Year 2000 challenge. The brochure explains the steps financial institutions and the federal financial institution regulators are taking to address the century date change and emphasizes that the Year 2000 situation will not affect deposit insurance coverage. Financial institutions may wish to use the brochure as part of their communications with customers. The brochure will be available in June 1998. Should you or your staff have any questions regarding the statements, please contact Sarah Dahlgren, Vice President, Bank Supervision Group, or William Francis or Thomas Wines, Examining Officers, Bank Supervision Group ( respectively).