Clarification of the FDICs Year 2000 Contingency Planning Policy
The Federal Financial Institutions Examination Council (FFIEC) has issued the attached
May 6, 1999, interagency statement clarifying expectations on testing Year 2000 business
resumption contingency plans, overall contingency planning documentation requirements, and
In FIL-135-98, issued December 11, 1998, the FDIC provided institutions a schedule for
completing contingency plans as described in the FFIECs May 1998 interagency
statement "Guidance Concerning Contingency Planning in Connection with Year 2000
Readiness." The FIL established March 31, 1999, as the deadline for institutions to
complete phase one (organizational planning guidelines) and phase two (business impact
analysis); and June 30, 1999, as the deadline for completing the business resumption
contingency plan. After the FIL was issued, many questions were raised about what
constitutes a complete business resumption contingency plan. The attached interagency
statement addresses those questions.
FDIC examiners will review business resumption contingency plans for all
FDIC-supervised institutions at the field office level. Regional or field offices will
contact each institution to request plans and additional documentation. Institutions will
soon receive mailing addresses, a description of required documents, and the deadlines for
submitting their contingency plans.
The FDIC and state banking authorities will continue to review the efforts of all
FDIC-supervised banks to become Year 2000 ready. An institutions failure to
appropriately address Year 2000 readiness issues may result in supervisory action,
including enforcement actions, denials of applications FILed pursuant to the Federal
Deposit Insurance Act, civil money penalties, reductions in the institutions
management component or composite ratings, and increased risk-related premiums.
Related information on Year 2000 issues is available on the Internet via the World Wide
Distribution: FDIC-Supervised Banks (Commercial and Savings)
NOTE: Paper copies of FDIC financial institutions letters may be obtained through the
FDICs Public Information Center, 801 17th Street, NW, Room100,
Washington, DC 20434 (800-276-6003 or (703) 562-2200).