Academic journal article ABA Banking Journal

Deadline Status: Firm

Academic journal article ABA Banking Journal

Deadline Status: Firm

Article excerpt

FDIC's Nick Ketcha, to put it plainly, was ticked.

Speaking at a recent industry gathering, he referred to a letter sent to bank clients by an insurance provider. The letter compared many of the Year 2000 concerns to the child's tale of Chicken Little.

"The sky did not fall and the Year 2000 will come and go with banking continuing to be a great business serving banking customers," the letter stated.

Ketcha, director of supervision at FDIC, cited the letter as an example of elements of the banking industry that aren't taking the issue seriously enough.

Fortunately, the industry at large seems to be recovering from an early, perceived lack of focus on the problem. And not a moment too soon. The Year 2000 is an issue with a key difference from any other regulatory challenge: its utter certainty of not being changed.

Congress can find many ways to ignore reality, but it can't repeal or stall the calendar. Bankers can't file for an exception based on size nor plead that other pressing matters have delayed preparations. Regulators can't amend, adjust, or postpone compliance.

So hankers and regulators keep pressing towards the ultimate deadline, with Congress looking over their shoulders. Both the House and Senate Banking Committees have held extensive hearings on the subject and both have passed bills directing regulators to hold seminars and propose model approaches to meeting the challenge.

Not that the regulators have been idle-far from it. They have been issuing a stream of advisories and have published dates that banks must meet (see page 66).

What's more, the regulators have been conducting on-site examinations of banks and certain vendors in an effort to determine where they stand thus far, This is a follow-up to an earlier round of off-site reviews of banks' strategies for meeting the challenge. And, as detailed in the accompanying article, "Could the Feds shut you down in 1999?" (p.44), the agencies have also been mulling their likely approach to banks that are not going to be ready in time.

In an industry where to do" lists are already chock full, Year 2000 is a "super priority."

"The Year 2000 area is our number one safety-and-soundness issue, says Michael J. Zamorski deputy director of FDIC's Division of Supervision and chair of its Year 2000 oversight committee. "Our examinations are risk-focused now (as are those of all the federal regulators), so this is a key issue in our ordinary' exams as well."

What the regulators are seeing

The federal banking agencies have been working towards their goal of examining every bank in the country for progress towards Year 2000 preparedness by the end of June 1998. As this issue went to press in mid-March, they had completed roughly half of the exams.

Thus far, the news is good. Take the findings of FDIC as a barometer. "Most of the banks we're seeing are making satisfactory progress--there aren't huge problems," says Michael Benardo, an examination specialist in the Division of Supervision.

Benardo says of the banks FDIC has examined to date about 20% have deficiencies in their efforts. Most of those simply need to focus more intensively on Year 2000 matters, says Zamorski, He notes, however, that 2% of all the banks examined are of serious concern. They have done little to address it, and may' even demonstrate little understanding.

In all, a pretty respectable showing by the industry, so far. However, says Zamorski, "you can have the best plan in the world, but if you can't execute it. ..." Many banks, especially community banks, rely on outside servicers for their processing, which is another aspect of the issue.

Indeed, besides ongoing examination and monitoring of banks, the agencies are looking at two other groups of players: 275 data processing servicers and 16 major software vendors. On-site examination of these companies was expected to be completed by the end of June. …

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