Answers to Frequently Asked Questions on Year 2000 Contingency

Letter To Credit Unions No. 98-CU-2, dated January 15, 1998, and Letter To Credit Unions No. 98-CU-12, dated June 10, 1998, provided guidance on contingency planning. The attached FFIEC paper provides additional guidance to credit union boards of directors and senior staff in developing their Year 2000 contingency plans.

A credit union should design its Year 2000 contingency plan to mitigate the risks associated with (1) the failure to successfully complete renovation or implementation of its Year 2000 readiness plan (remediation contingency plan), and (2) the failure of systems at critical dates (business resumption contingency planning).

The attached FFIEC Question and Answer paper contains a milestone date of June 30, 1999, for the completion of Year 2000 Business Resumption Contingency Plans. NCUA has adopted this milestone date.

The FFIEC paper also makes references to other dates, unique to financial institutions regulated by the FFIEC participants; credit unions should refer to NCUA guidance for all milestone dates.

NCUA recognizes that the complexity of a credit union’s Year 2000 business resumption contingency plan will vary depending upon the complexity of its information system structure. However, credit unions are expected to develop, implement, and validate Year 2000 contingency plans designed to mitigate the risks associated with the Year 2000 date change. The Year 2000 contingency plan should be in writing and documented to support the conclusions and procedures set forth in the plan. The board of directors and senior staff are responsible for ensuring the Year 2000 contingency plan is comprehensive and adapted for the unique attributes of their credit union.

If you have questions or comments, please contact your examiner, regional office or state supervisory authority.