Year 2000 Computing Crisis

Office of Thrift Supervision's Efforts to Ensure Thrift Systems Are Year 2000 Compliant Gao ID: T-AIMD-98-102 March 18, 1998

This testimony discusses the Office of Thrift Supervision's (OTS) progress in ensuring that the more than 1,200 thrifts it oversees are ready for the upcoming century date change. If Year 2000 issues are not adequately addressed, key automated thrift systems affecting hundreds of billions of dollars in assets, transactions, and insured deposits are vulnerable to serious consequences--from malfunction to failure. At a minimum, banks and their customers would be inconvenienced. More ominously, system failure could lead to thrift closings and serious disruptions for both the thrift industry and its customers. GAO also discusses OTS' progress in addressing Year 2000 issues affecting its own internal systems.

GAO noted that: (1) the year 2000 problem poses a serious dilemma for thrifts due to their heavy reliance on information systems; (2) regulators have a monumental task in making sure that financial institutions have adequate guidance in preparing for the year 2000 and in providing a level of assurance that such guidance is being followed; (3) further, regulators will likely face some tough decisions on the readiness of individual institutions as the millennium approaches; (4) GAO found that OTS is taking the problem very seriously and is devoting considerable effort and resources to ensure the thrifts it oversees mitigate the year 2000 risks; (5) despite aggressive efforts, OTS still faces significant challenges in providing a high level of assurance that individual thrifts will be ready; (6) in fact, the problems GAO found at OTS are generally the same as those found at the other regulators reviewed; (7) OTS was late in addressing the problem and consequently, is behind the year 2000 schedule recommended by both GAO and the Office of Management and Budget; (8) in addition, key guidance--being developed under the auspices of the Federal Financial Institutions Examination Council (FFIEC)--needed by thrifts and other financial institutions to complete their own preparations is also late which, in turn, could potentially hurt individual institutions' abilities to address year 2000 issues; (9) OTS needs to better assess whether it has an adequate level of technical resources to evaluate the industry's year 2000 efforts; (10) these problems hinder the regulators' ability to develop more positive assurance that institutions will be ready for the century date change; (11) consequently, the challenge for them at this point is how can they use their resources from here to the millennium to ensure that thrifts, banks, and credit unions mitigate year 2000 risks; (12) OTS has done much to mitigate the risk to its mission-critical internal systems and has already renovated, tested, and implemented 13 of its 15 mission-critical systems; (13) however, it has not yet completed contingency plans necessary to ensure business continuity in case system renovations or replacements are not completed in time or do not work as intended; (14) compounding this problem is the fact that OTS has not developed a comprehensive year 2000 conversion program plan providing a clear understanding of the interrelationships and dependencies among the automated systems that support, for example, its supervisory functions, office equipment, and facilities; and (15) such a plan provides added assurance that all systems are assessed.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

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