|
The Federal Reserve has suggested that regional Fed banks begin pressuring banks to get compliant. Sometime soon, the banks must have their inventory completed.
The
California White Paper says that awareness is 1% of the job. Inventory is 1%. Assessment (the plan of action) is 5%. So, sometime in early 1998, banks MUST have at least 7% of the job finished, or else the Fed may impose penalties.
The Fed expects a bank's entire code renovation to be finished before the end of 1998. That means something in the range of 35% to 40% of the job . . . done in less than a year.
Social Security began in 1991. They aren't at the half-way point yet.
My view: the free market will impose the penalties in 1999. The market is merciless.
* * * * * * *
In the event that the supervisory process identifies any banking organization that does not now have such an inventory of mission critical systems and a plan that will enable renovation to be largely completed with testing well under way by year-end 1998, a multi-stage process should be initiated by the Reserve Bank to ensure that the organization immediately starts receiving all appropriate supervisory attention. . . .
If a banking organization's corrective action plan is inadequate and cannot be enhanced expeditiously, or an organization fails to submit any required remedial plan or fails to take actions to follow its already submitted plan in a satisfactory manner, the Reserve Bank should promptly consider the imposition of an appropriately tailored enforcement action. The failure to dedicate sufficient resources to solve identified problems and the adequacy of senior management's attention to Year 2000 compliance issues should be among the most critical determinative factors in deciding the nature of the follow-up enforcement action. Possible enforcement actions in the case of serious deficiencies could include written agreements, cease and desist orders and civil money penalties.
|