Circular
Additional FFIEC Questions & Answers on Y2K Contingency Planning
May 20, 1999
Circular No. 11154

"Year 2000 Readiness Disclosure"

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:

TheFederal Financial Institutions Examination Council (FFIEC) has issued additional guidance on Year 2000 contingency planning. (Previous FFIEC guidance on contingency planning was contained in our Circulars Nos. 11057 and 11127.)

The new guidance, in the form of questions and answers, clarifies expectations concerning the completion of the validation phase of business resumption contingency planning by June 30, 1999, documentation requirements, and the role of "event planning" in the development of contingency plans. Specifically, it indicates that financial institutions should substantially complete contingency plans by the June 30th milestone. The testing and validation of the plans may be executed after June 30, 1999, but should be completed early enough to allow ample time to make changes and retest the plan, if necessary.

A copy of the FFIEC release and guidance is available. Questions on this matter may be directed, at this Bank, to Sarah Dahlgren, Vice President, Bank Supervision Group, or to Ira Adler or Joseph Galati, Examining Officers, Advisory and Technical Services, Bank Supervision.