Year 2000 Bank Examinations: the regulators have arrived

In the last issue of the Financial Services Regulatory Report, we addressed the concern that, despite the issuance by the FFIEC of Y2K guidance for the last two years, many bank Y2K compliance efforts have been inadequate or non-existent (see "Y2K Compliance Examinations: Are You Ready for Your Regulator?" Vol. 5 No. 6). Specifically, we reported on the assertive guidance issued by the FFIEC on October 15, 1998, "Interagency Guidelines Establishing Year 2000 Standards for Safety and Soundness" (the "October Guidelines"), which contains the first specific discussion of regulatory enforcement actions that might be taken in response to inadequate Y2K preparations, including the requirement that an institution submit an acceptable compliance plan to its regulator.