The vast majority of credit unions are well prepared for the century date change. Currently, 99.5% of credit unions are rated, “Satisfactory,”NCUA’s highest rating. Of the credit unions which are rated “Less than Satisfactory,” plans are in place to ensure these institutions are ready for the century date change. NCUA is confident that all federally-insured credit unions will be ready for the Year 2000.
During the remainder of this year, credit unions will be making final preparations for the century date rollover. This letter describes the following important considerations for credit unions during this period:
- Communications with your members,
- Contingency planning - issues NCUA is observing during our reviews,
- Final opportunity testing,
- Operating hours during the century rollover event, and
- Developing an event rollover plan.
This letter will also discuss three NCUA “Century Date Rollover”initiatives:
- Response teams,
- Asset liability backup requirement for credit unions rated less than satisfactory, and
- Credit union “health checks” during the century date rollover weekend.
Communication with your members
Effective communication is essential when informing your membership about your efforts to prepare for the century date change. Your members’ perceptions of your Year 2000 readiness will be determined to a large extent by how you choose to communicate with them. You should actively communicate with your members about the Year 2000 date change; credit unions that wait for members to initiate communication will allow others to have an impact on their members’ perception of the credit union’s readiness. Do not allow 2 sensational news reports to be the only information your members hear about the Year 2000 date change.
Ensuring your membership has access to timely, accurate information is critical. It is not uncommon for computer systems to be periodically unavailable for reasons such as system maintenance, communications disruptions, or power outages. As we approach the century date change weekend, it is likely that normal interruptions in service may be misinterpreted as Year 2000-related problems. Recently, there was a news story about an ATM machine which failed to work on September 9, 1999. Because this date was a potential Year 2000 problem date, many believed the ATM’s failure was related to the Year 2000. Due to the credit union’s proactive communication efforts, NCUA and the membership quickly learned that the ATM’s failure was completely unrelated to the Year 2000.
Credit unions are in the best position to communicate with their members about the Year 2000 readiness of their credit union and should be actively involved in that process now.
Year 2000 communication strategies can be found through many sources. Credit unions might find useful the “Y2K Communication Kit,”which can be found on the web site: http://www.cuy2k.org, under the heading “Member Issues.” Another source of communication information is the FFIEC1 web site which contains a document titled “Year 2000 Customer Communication Outline,” (http://www.ffiec.gov/custom.htm). A number of other organizations, including credit union leagues and the President’s Council on Year 2000 Conversion (web site http://www.y2k.gov), have also published communications plans. Appendix A contains additional information on communication plans.
NCUA has published a number of documents on contingency planning, beginning with the FFIEC letter on contingency planning (all available on NCUA’s web site - http://www.ncua.gov). As credit unions review their contingency plans, they should ensure the following elements are considered:
- Board of Directors delegation of authority,
- Management delegation of authority,
- Reciprocal disaster recovery agreements,
- Staff and vendor communications,
- Contingency plans of information system service bureau vendors, and
- Data backup procedures.
See Appendix B for more discussion on each of these elements.
Final Opportunity Testing
Credit unions have an opportunity to operate their computers on Saturday, January 1, 2000, and Sunday, January 2nd. This “final opportunity” provides credit union management with an opportunity to test their computer systems in a “real” Year 2000 environment, providing officials one last opportunity to exercise their due diligence in managing the century date change. This also will provide officials time to initiate contingency and communication plans, should the unexpected occur.
Operating Hours During the Event
Some credit unions are considering staying open late on Thursday, December 30, 1999, to assure their members that all is well; others are considering closing early to ensure ample time to perform end-of-year processing and last minute testing. Some credit unions normally close the entire last week of December should their sponsor be closed. Some credit union officials have asked for NCUA’s position on operating hours during the final days of 1999.
NCUA believes that management must determine the best approach for their institution in regard to operating hours. Many credit unions believe that a “business as usual” approach is most appropriate. Should you decide to operate on a different schedule than your normal operating hours, it is imperative that this change be communicated to your membership, so that your members do not develop unwarranted concerns.
Developing an Event Rollover Plan
Credit unions should consider developing an “Event Rollover Plan” to coordinate the events involved during the actual century rollover. An “Event Rollover Plan” describes the operational steps the credit union will take during the transition from 1999 to 2000. This document identifies the operational procedures and timing of events that will occur from year-end data processing through the date rollover to the opening of the new year. An “Event Rollover Plan” should be developed with input from your information systems vendors.
Please see Appendix C for additional information on “Event Rollover Plans.”
Asset Liability Backup
Credit unions which are rated by the NCUA as less than satisfactory, as of September 30, 1999, in their Y2K preparations, will be required to prepare a standard data set of loan and share information known as an “Asset Liability Backup” (ALB) file. The file layout of the ALB can be found in Appendix D. Credit unions subject to the ALB program will be notified and provided more information by their examiners and their regional directors.
NCUA Response Teams
In conjunction with NCUA’s Business Resumption Plan, a supervisory response team initiative has been established to deal with emergency situations resulting from the Y2K date conversion. Each region, along with various state supervisory authorities, has designated staff to serve on special “response teams” and will be mobilized as needed to address any major system disruptions or failures that may render a credit union’s systems inoperable. These teams will be deployed in circumstances where the credit union’s contingency plan fails to restore critical systems and the credit union’s business viability is in question.
Credit Union “Health Checks”
NCUA will be collecting “health check” information from all credit unions during the century date rollover weekend. Expect a call from your NCUA examiner or your State Supervisory Authority. Health check information will be summarized and will be available for NCUA internal management as well as for release to the President’s Year 2000 Information Center and the media.
Credit unions are well prepared for the century date change. Ensuring a smooth transition involves planning for the unexpected, maintaining effective communications, and executing a coordinated rollover. During the remaining months of 1999 the credit union community will need to cooperate through effective communications, proper contingency planning, and coordination of efforts that maintains your member confidence in the credit union financial system.
Norman E. D’Amours
Chairman, NCUA Board
1The FFIEC is the Federal Financial Institutions Examination Council and consists of the National Credit Union Administration, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision.