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Summary and Comments

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Category: 

Banking

Date: 

1998-04-16 19:58:34

Subject: 

Why U.S. Banks Cannot Possibly Make It

  Link:

http://www.ffiec.gov/y2k/guidance.htm

Comment: 

The FFIEC, which is a joint committee that coordinates the regulators of the banking and thrift industries, estimates that 50% to 60% of a y2k repair is testing. This is a conventional estimate.

No bank is at the testing phase yet. No U.S. bank seems to have started its y2k project prior to 1995. The deadline is 2000. So, it has taken at least three years for them to get into the code repair stage (at best). That is more than 2.5 years. They are beyond the fail-safe date.

But this assumes that there will not be worldwide bank runs in 1999, when depositors figure out the obvious: the banks won't meet the 2000 deadline.

Notice that the recommended mid-term deadlines do not reflect the assessment of 50%. They in fact deny the 50% figure.

* * * * * * * *

The FFIEC estimates that testing will consume 50 to 60 percent of the time, funding, and personnel needed to make financial institutions Year 2000 ready. Testing is critical to ensure that remediation efforts work effectively. Financial institutions must test because of the widespread changes being required to become Year 2000 ready. The software and hardware changes may not affect only one isolated application or system, but they may affect many or all internal systems and interfaces with internal and external entities. . . .

June 30, 1998

Institutions should complete the development of their written testing strategies and plans.

September 1, 1998

Institutions processing in-house and service providers should have commenced testing of internal mission-critical systems, including those programmed in-house and those purchased from software vendors. December 31, 1998

Testing of internal mission-critical systems should be substantially complete. Service providers should be ready to test with customers.

March 31, 1999

Testing by institutions relying on service providers for mission-critical systems should be substantially complete. External testing with material other third parties (customers, other financial institutions, business partners, payment system providers, etc.) should have begun.

June 30, 1999

Testing of mission-critical systems should be complete and implementation should be substantially complete.

Link: 

http://www.ffiec.gov/y2k/guidance.htm

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