Letter To Credit Unions No. 9 8-CU-2, dated January 15, 1998, provided guidance on contingency planning. The attached FFIEC paper provides additional guidance to credit union boards of directors and senior staff in refining their Year 2000 contingency plans. A credit union should design its Year 2000 contingency plan to mitigate the risks associated with (1) the failure to successfully complete renovation or implementation of its Year 2000 readiness plan (remediation contingency plan) and (2) the failure of systems at critical dates (business resumption contingency planning). Business resumption planning is critical in the event of failure of telecommunications networks, telephone lines, power grids, and water and sanitation systems.
Although previous FFIEC releases have addressed remediation contingency planning, the last section of the attached guidance paper provides clarification of that guidance. How ever, the primary subject of the attached paper is business resumption contingency planning and addresses the following areas:
- Each credit union’s board of directors and senior staff must ensure the Year 2000 contingency plan is comprehensive and adapted for the unique attributes of their credit union to ensure the credit union can continue as a functioning business after January 1, 2000.
- Each credit union should design its Year 2000 business resumption contingency plan to provide assurance that mission-critical functions will continue if one or more systems fails.
- Each credit union must continuously develop, implement, and validate their Year 2000 contingency plans to mitigate the risks associated with the Year 2000 date change.
If you have questions or comments, please contact your examiner, regional office or state supervisory authority.
Norman E. D’Amours
Chairman of the Board