Hoping someone can help me -
The agencies have issued a proposal To Strengthen the Resilience of the U.S. Financial System - Sound practices apply most directly to "core clearing and settlement organizations" and "financial institutions that play significant roles in critical markets."

I work for an IT processor and we handle clearing and settlement for multiple FI's, but are we considered critical? How do I determine if this affects us?

The regulators are stating that if you have a major impact on the US economy if you are not up and running within 8 hours it's critical. We process millions of dollars in settlement but if there was a disaster that knocked one of our sites out for 72 hours we could recover and impact to the US economy would be minimal at best.

Any ideas on where the regulators are going with this? What would they consider as critical?

Thanks for any help you can provide.

I have not heard of this legislation, can you give us a reference and allow us to read it and maybe we can help you out.

It was published in the Federal Register on 9/5/02.

Here is the URL for the proposal - http://www.federalreserve.gov/boarddocs/press/bcreg/2002/20020830/default.htm

I would appreciate your thoughts on this.

Thanks

Well, from reading the FIL it makes me think of a couple of things. First, remember how the payment system was so drastically affected immediately after 9/11? The Federal Reserve actually received government permission to fly airplanes during that time to be able to keep the financial payment systems from becoming stiffled. Also, with the major financial services in the vicinity of the WTC that either was totally disabled or partially disabled by the events, it was so critical to have disaster recovery sites established in another region so as to be able to resume operations if a "catastrophic" event were to occur. It doesn't do any good to have a backup center two blocks away, and I think that is partially what they are getting at. After 9/11 the government wants to ensure that if a particular region (city, counties, state) were to sustain a major disabling event that there would be sufficient planning to allow virtually immediate resumption. Whew. That said, I would look at who you process for, the dollar and transactional volume that you process. Is it for a few banks or for several hundred? The way that I interpreted the letter was MAJOR financial service providers such as the Federal Reserve offices, Wall Street, major bond traders, probably the Bank of Americas, and any regional clearing houses that service many. We all had to learn a lesson from 9/11 in that we have to look at our contingency plans and re-evaluate the practicality of what we put to paper. They just want to know that your contingency plans are adequately designed and you will be able to resume operations within an expediant amount of time. If you are questioning wether or not you are a "big" player you are apparently processing enough that maybe you should consider yourself as such and go ahead and prepare accordingly, worst thing that can happen is that if something were to happen to your region, you have the peace of mind that your branch of the process will not be crippled by the event.

Thanks for your help. We have the ability to recover within 48 hours but not the 4-8 hours the Fed. is asking for. Time to take this up the management chain and see what happens. Thanks again.