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The TD Bank is working on assessment. According to the
California White Paper, assessment is about 5% of the job, after awareness (1%) and inventory (1%).
The bank is vague about whether its staff has begun to correct code, or how many lines of code it has to correct, or how many programmers are working on this, or where it is into the code remediation process. It does not mention vendor-supplied software. Is this compliant? The document speaks of "a plan" and "our general strategy." Plans and strategies are important. So is correcting code.
It assures us that the job will be done in late 1998. This is the universal promise.
"Our approach has been to be proactive on this issue and we are confident that our systems will be ready for year 2000." But I am aware of no company on earth that has issued a report that says: "Our approach has been to do nothing on this issue and we are not confident that our systems will be ready for year 2000." In short, this is a standard press release. It's what banks issue to prevent bank runs.
What depositors should ask for is evidence, not the bank's self-promotion.
The press release makes a promise: "We will provide status updates on this site as we progress with this activity." I looked. I did not find anything. I'll look again. So should the bank's depositors.
The press release ends with this:
"For more information concerning TD's Year 2000 initiative contact Year 2000 Project Office, TD Centre, Aetna Tower, 16th Floor, Toronto, M5K 1A2."
Here is what I suggest that depositors ask about:
1. The number of lines of code to correct.
2. The number of programmers working on this project. (The average programmer can go through 100,000 lines a year and make needed corrections.)
3. The number of software vendors that supply system software.
4. How many of these vendors have supplied compliant updates.
5. The strategy adopted to keep noncompliant data from noncompliant banks from corrupting TD's data.
6. The source of supply of the added 100% in computer capacity to run the parallel testing in 1999.
7. How many months the bank intends to run the parallel tests in 1999.
This is from the bank's web site.
* * * * * * * *
The consequences of the Year 2000 Issue are extensive and will affect all government, corporate, small business and personal computers if not corrected. Organizations must examine all computer systems to determine if they are affected and take corrective action to modify those that are. Only after an organization has taken corrective measures for all of its computer systems will it be considered Year 2000 Compliant. In many cases this activity will also require that an organization ensure that its customers and suppliers are also Year 2000 Compliant. It is estimated that in Canada alone the cost of correcting the Year 2000 Issue is about $12 billion.
TD Bank's Response
TD is taking a comprehensive and careful approach to the challenge presented by the many systems that require change to accommodate the Year 2000 Issue. We have been working on this issue since 1995 and have gathered an inventory of potential impacts throughout the Bank. We have a plan in place that will enable us to identify and correct our systems before they become a problem. The resources required to do this work have been allocated and the work is well underway to implement the many changes required to ensure a seamless transition for our customers.
For our larger computer systems our general strategy is to correct the problem using logic rather than expanding the date fields. This reduces the risk of interdependencies and makes the process more manageable allowing us to implement each component as it becomes compliant. For our smaller systems (i.e., Personal Computers) most software and hardware are scheduled to be upgraded to compliant versions prior to year 2000 through normal replacement programs. Our approach has been to be proactive on this issue and we are confident that our systems will be ready for year 2000. TD has positioned Year 2000 compliance as a top priority for the next two years. The Bank's executive are committed to the program and they review progress on an ongoing basis.
Timing
We fully expect to have all the required changes made and individually tested by the end of 1998. Testing will include simulating dates prior to, during and after January 1, 2000. Throughout 1999 we plan to run a fully integrated test of all our critical systems to ensure that they work together using year 2000 dates. This will include testing of our interfaces to our critical suppliers and merchants by the middle 1999. We will provide status updates on this site as we progress with this activity.
Management
We have established a Year 2000 Project Office to co-ordinate our efforts. This group sets and communicates conversion standards, ensures all areas of the Bank are involved and acts as overall project manager. For more information concerning TD's Year 2000 initiative contact Year 2000 Project Office, TD Centre, Aetna Tower, 16th Floor, Toronto, M5K 1A2.
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