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Financial Institution Letter
Remaining Year 2000 Risks

SUBJECT: Outstanding Risks Associated With the Year 2000

As a result of the banking industry's comprehensive Year 2000-readiness preparations, no substantive problems occurred during the date change period. However, while the industry can generally claim success, some associated risks remain. They involve certain critical dates, the expiration of temporary remediation techniques, records retention and customer risk.

Critical Dates

The following are critical dates that may cause system problems. Many of the dates were included in test scenarios. Institutions should review processing results closely.

February 29, 2000

Leap year date

March 31, 2000

End of first quarter of 2000

October 10, 2000

First date to require eight-digit field

December 31, 2000

Last date of year

January 1, 2001

First date of year

December 31, 2001

Ensure 365-day year

The FDIC's examination staff plans to contact certain institutions immediately following February 29, 2000, to determine the status of their information system operations.

Temporary Remediation Techniques

Institutions that used temporary techniques, such as "windowing," to remediate systems should plan to replace or repair these systems as needed. Plans should be established in sufficient time to allow for an orderly and timely transition, with a minimum of operations disruption. Examiners will review these plans during regularly scheduled examinations.

Records Retention

Each institution should retain the documentation of its Year 2000 efforts to demonstrate it has satisfied its fiduciary, contractual and regulatory responsibilities. Management may wish to seek legal counsel on the suitability of its institution's records retention system.

Customer Risk

In 1998, the Federal Financial Institutions Examination Council issued guidance to institutions about the Year 2000's potential impact on customers. The statement provided guidelines for controlling both general and specific risks related to borrowers, depositors and capital markets/asset management counterparties. Management should continue to monitor the potential customer risk for the remainder of the year.

Throughout this year, the FDIC expects its supervised institutions to continue to report any significant Year 2000-related problems.

For further information, please contact your Division of Supervision Regional Office.

James L. Sexton

Distribution: FDIC-Supervised Banks (Commercial and Savings)

NOTE: Paper copies of FDIC financial institution letters may be obtained through the FDIC's Public Information Center, 801 17th Street, NW, Room 100, Washington, DC 20434 (800-276-6003 or (703) 562-2200).

Last Updated: February 17, 2000