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There is a great deal of concern, rhetoric, finger-shaking, and dire predictions about the year 2000. Our examiners are focusing on it-it's the first set of questions they want to address these days. They aren't interested in CRA, or Truth in Lending, or security procedures. At least not until they've found out where you are in your planning or preparation for the year 2000. They want to know what you've done, who's doing it, how far you've come along, how much you've spent on it, who's in charge, is upper management aware of everything, where is it written down, when will it be done and have you tested it?
And then what do you know about your customers' preparedness? You're supposed to "know your customer", remember? Have you been informed of their procedures and what they've done?
"Do you realize," you'll be asked, "what kind of trouble you're in if you haven't anticipated every possible thing that could happen?"
The ironic part about all the pressure being put on the banking industry by the examiners, the regulators and the government is the fact that we are heads and shoulders ahead of other industries in preparing for the millennium, and light-years ahead of the government. From all reports, government offices and departments in Washington, DC are trying to "fix" their systems using what is fondly called the "band-aid" approach, meaning they'll fix it better when they have time. (Ever clean drawers that way? Know what happens then?) Many of their computers and programs are antiquated and possibly "unfixable" in the time frame left. Some are so old, according to IRS sources, they are completely unusable given any time frame.
Congress has been really busy during the past year telling the banking industry what is wrong with it, instructing us what to charge and how to do business, what we have to report and when, and threatening us with fines and restrictions when we don't meet the standards they have determined are satisfactory to the consumer. And now they're taking a hard line on Y2K, saying they'll take action against those financial institutions they feel are not ready enough.
The Bible refers to this type of criticism when it advises to "remove the log from your own eye before complaining of the splinter in mine." (Note: Very loose translation.)
All of the people in the banking industry that are involved with the changeover must really want to tell the doomsday soothsayers, " Chill out! We'll handle it!"
Personally, I have a great deal of faith in the banking industry. I know the regulators say a bank should not claim to be "completely ready." But I believe that when we finally close our doors on Friday, December 31, 1999, we'll go home knowing that Monday, January 3, 2000 will be just another business day for us. And it will be. Unless the direct deposit for social security has been screwed up by the government's computers!
The only problem we'll have, as in every other new year, is reminding our customers how to correctly date their checks. The difference this time will be the first number, not the last. "Ooooops, you don't need a 1 there, you need to write a 2!" Come to think of it, maybe we should practice that so we can tell the examiners we'll be ready for that too.
Copyright © 1998 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 8, No. 6 5/98
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