Mr Ferguson looks at the challenges to the US payments system posed by the Year 2000
problem
Remarks by Mr Roger W Ferguson Jr, a member of the Board of Governors of the US Federal
Reserve System, before the National Automated Clearing House Association in Atlanta, Georgia
on April 13, 1999.
The Payments System and Year 2000: Current Preparations and Challenges
Thank you for your invitation to speak today on the timely and critical topic of the Year 2000
challenge to the payments system. As an industry, we have a tremendous responsibility to the
public to ensure the smooth operation of the payments system through the Year 2000 and beyond.
This morning I would like to discuss the global challenge presented by the Year 2000 problem
and describe international efforts, particularly those of the Joint Year 2000 Council, to assist the
worldwide financial services industry to be ready for the century date change. In particular, I
would like to focus on contingency and risk management initiatives undertaken by central banks
and the state of readiness of Federal Reserve payment systems, such as Fed ACH. Finally, I will
discuss our need to recognize our responsibility to the general public and our need to continue to
develop cooperative efforts between public-sector and private-sector organizations.
Global Challenge
With less than a year left before the millennium change, it still remains difficult to judge its
global impact. The good news is that we are not faced with inaction and there are early
indications that the financial industry, in general, is working diligently to be prepared. The euro
conversion, which I will elaborate on later, demonstrates that the financial industry can manage
significant changes to its systems. It is also important to note, however, that the Year 2000
deadline is not a single event; it is arriving in stages based on dates typically used in financial
systems that give us an "early warning" of potential problems. As an example, for any financial
systems that look ahead one year, the early January 1999 dates provided a test of their Year 2000
readiness. During 1999, other application look ahead dates will provide further indications of our
readiness as well as our ability to initiate our contingency plans.
Given the sheer number of computers and chip-based systems, and the manual nature of the fixes
that have emerged to date, we are likely to experience some degree of disruption. I believe most
disruptions will prove to be mild and short-lived and, as reported in a recent article, their severity
effect will be labeled as "headaches, not disaster." Consequently, I do not think that we will face
global recession. Ultimately I believe the number and extent of computer system disruptions will
not be used as the measure of our success in addressing the Year 2000 problem. Instead, our
success will be measured by our ability, and the public's confidence in our ability, to conduct
business operations effectively for the balance of this year, on January 3, 2000, and thereafter.
Current State of International Year 2000 Efforts
Some foreign governments and institutions started their Year 2000 program years ago, while
others were initially reluctant to recognize that a problem even existed. This reluctance hindered
efforts to take early action. In some areas, already limited resources were dedicated to other
activities, such as the euro conversion or attempts to restructure weakened economies. Those
countries that recognized the problem early and had sufficient resources assembled technical
experts from whatever source was available. Recognizing these challenges, in April 1998 the
Bank for International Settlements hosted a Year 2000 roundtable to raise international
awareness. At the close of the conference, the sponsoring organizations, the Basle Committee on
Banking Supervision, the G-10 Committee on Payment and Settlement Systems, the International
Association of Insurance Supervisors, and the International Organization of Securities
Commissions established the Joint Year 2000 Council. The Council was formed as a direct result
of the recognition of the complexity of the global financial services industry and the need to
communicate proactively with regulatory and supervisory authorities.
As Chairman of the Joint Year 2000 Council, I work with other members of the Council to ensure
that a high level of attention is given to the challenge within the global financial supervisory
community and to serve as a point of contact with national and international private sector
initiatives. To that end, the Council operates with the participation of central banks, insurance and
securities regulators, and banking supervisors. It is the first international body that brings together
such a range of financial regulators. It is important to note that the Joint Year 2000 Council is not
the "international Year 2000 enforcement agency." We do not have on-site examiners, nor are we
meant to replace the efforts of national regulators.
The Council established an External Consultative Committee, or ECC, to enhance the degree of
information sharing between the public and private sectors. This committee includes
representatives of internationally-oriented organizations including the Global 2000 Coordinating
Group, the International Monetary Fund, the World Bank, and financial service providers, such as
S.W.I.F.T., Euroclear, and Cedel. Our most important role may be to provide a forum to facilitate
information sharing and cooperation among supervisors. To accomplish this, we have developed
a global supervisory contact list of over 600 financial regulators and have initiated several
mechanisms for communicating with them. Our most visible may be a series of bulletins, which
come out monthly, on different themes and topics. Additionally, the Council has, and will
continue to, support, cosponsor, and provide assistance in planning conferences and roundtables
on the Year 2000 challenge. To date, we have conducted meetings for regulators from Europe,
Asia-Pacific, North and South America and the Caribbean, Africa, and the Middle East, which
have provided an excellent means of bringing supervisors together to discuss common interests
within specific geographic areas.
What is the state of "international readiness?" As you can understand, it is difficult to measure
accurately the level of international Year 2000 readiness, and certainly no one can predict with
confidence exactly how the century date change will unfold internationally. There are three
reasons for this difficulty. First, there is no single indicator that can be used to judge the overall
Year 2000 readiness of any country, including the United States. Second, the state of readiness is
a moving target. Judgements are usually based on anecdotal information obtained either first-hand
through interviews or surveys or second-hand through other sources. The best information is
subject to change. Finally, while it may be possible to reach conclusions about the Year 2000
readiness of individual industry sectors, it remains difficult to assess the interdependency of
critical systems across industry sectors. In addition, the state of Year 2000 readiness of a
country's public sector may not be an accurate indicator of the status of its private sector.
With that said, I believe that, as with the United States, in most countries the financial sector was
probably somewhat ahead of other sectors in recognizing the Year 2000 problem, and is probably
somewhat more advanced in testing and business continuity planning. The banking agencies here
in the United States have recently finished Phase II evaluations. Of the banks that the Federal
Reserve supervises, about 95 percent are making satisfactory progress. Of importance, the same
number of 95 percent applies to foreign banking organizations operating here, which as a group
had been behind their U.S. counterparts. I can also report that, through the regional meetings of
regulators that I referred to earlier, we have now had contact with regulators from over 100
countries, and the degree of awareness among regulators is, I find, uniformly high.
Similarly, with respect to regulators, I should mention the recent release of a statement by the
Basle Committee on Banking Supervision discussing the results of its second supervisory survey
on the Year 2000 issue. The statement highlights the need for continued efforts, especially in
several smaller jurisdictions. It is noteworthy, however, that the Committee's survey of more than
100 regulators identified significant progress within the global financial community. A large
majority of regulators indicated that they have issued specific Y2K-related guidance to their
banks and believe their banks are taking appropriate steps to address the issue. I believe that these
results illustrate the benefits of global supervisory cooperation in raising the financial industry's
awareness of the issue and in spurring action.
Overall, no one can know with certainty the global impact of the century date change. While
much good work is being done, much remains. Banking institutions, both domestic and foreign,
must not allow complacency to set in.
Lessons Learned
As I noted earlier, there were concerns last year that scarce programming resources in Europe
were primarily focused on the euro conversion and that Year 2000 readiness efforts lagged. The
euro conversion is completed and its success can best be measured by its perception by the media
and public as a non-event. While the scale of system changes involved in the euro conversion was
significantly less than the Year 2000, the characteristics of the problem are similar and the Global
2000 Coordinating Group conducted a workshop on the euro conversion to identify "lessons
learned" that could improve Year 2000 preparedness. The results are valuable and I would like to
use them as a framework for describing payment system readiness efforts underway at the Federal
Reserve.
The first lesson was the need for suppliers of liquidity and credit management to offset payment
and funding dislocations. Central banks were urged to accept responsibility for these issues and
be able to make decisions with "less than perfect information." The Federal Reserve has taken
steps to increase its currency order and to be prepared to provide any necessary liquidity over the
year-end through open market operations and discount window lending. We are reminding
depository institutions that the Federal Reserve is available to meet liquidity needs under
appropriate circumstances and encouraging those that are including the Federal Reserve, as a
lender of last resort, in their Year 2000 liquidity contingency plans to complete necessary
discount window documentation and collateral arrangements as soon as possible. We are also
meeting with agencies such as the Federal Housing Finance Board and the National Credit Union
Administration to discuss liquidity issues that might affect the institutions they supervise.
Another lesson of the euro conversion was the need to provide for timely and accurate
information sharing between industry participants and with regulators. Effective information
sharing structures, such as communication centers, must be set up that enable fast and reliable
communications between market participants; among commensurate organizational levels, from
senior management through operations; and with regulators. Although the Federal Reserve has
demonstrated its ability to manage crisis situations, we are evaluating and augmenting our
existing communication structures where appropriate. We are developing local and national event
management centers to maintain a consistent flow of information within the Federal Reserve,
with our business partners, and with the public at large.
Regarding this last point, we are in the process of improving our information sharing with our
most critical supplier, the telecommunication industry, through our participation in the
Telecommunications Sector Group of the President's Council on Year 2000 Conversion and links
with the Federal Communications Commission (FCC). The Joint Year 2000 Council is
undertaking initiatives that will improve cross-border information sharing between countries,
particularly plans for business resumption and event management.
The third lesson is the need to expand contingency planning beyond operations, to address
business continuity, coordinate planning with third-party providers, and test these plans. We
established a Century Date Change Council, comprised of senior management officials, to direct
the Federal Reserve's approach to business continuity and contingency planning for the Year
2000. The Council considers risk mitigation actions to lessen the likelihood of a problem
occurring and to reduce the impact if a problem should occur; and oversees development of
contingency response procedures in the event problems do occur.
The Federal Reserve's planning for Year 2000 business continuity is well underway. Each
business completed an assessment of the adequacy of its existing contingency scenarios for Year
2000 problems last June. In addition, last November each Federal Reserve entity servicing
customers documented its plans to respond to the possibilities of customer problems. Although
the responsibility for having sound contingency plans lies with the management of the depository
institutions, we recognize that Federal Reserve preparations to deal with potential customer
problems are an important component of our business resumption planning. Our emphasis now is
on continuing to monitor, and where possible, reducing risk and on refining the Federal Reserve's
plans through testing, independent reviews, and other means of coordination.
Lastly, and not surprisingly, many problems that did occur with the euro conversion could have
been identified with more thorough testing. Since mid-year 1998, the Federal Reserve has offered
customers the opportunity to test future-dated transactions for payment applications, such as Fed
ACH, and other services with electronic data exchanges. We are continuing to offer testing
opportunities both during the week and on weekends through early 2000 and, in the second half
of 1999, opportunities will be provided to revalidate application readiness and to test contingency
procedures. As of the beginning of April 1999, over 6,200 institutions had tested with Fed ACH
and approximately 94 percent of our larger-volume ACH customers have tested.
I am also encouraged by the testing efforts of private service ACH operators. In February, all
ACH operators exchanged files future dated to the rollover weekend and a second test is
scheduled for May 10. The Federal Reserve and NYACH will test using leap year dates this
weekend.
We strongly support domestic and international testing efforts by major market participants, such
as the New York Clearing House, the Securities Industry Association, and S.W.I.F.T. to test
critical data exchanges. Under the leadership of the New York Clearing House and with the
support of the Federal Reserve, cross-border testing of major payment transactions and S.W.I.F.T.
is planned to take place in June 1999. For all countries participating in this test, June 12 will
conform to January 3, 2000; and June 13 will conform to January 4, 2000, the first business day
on which all major international money markets are open after the century rollover.
Public Outreach
The Joint Year 2000 Council strongly recommends enhanced information sharing as critical to
readiness efforts and to avoid unnecessary uncertainty in financial markets. In many countries,
there is currently a lack of adequate information on Year 2000 readiness. This is of concern
because it impedes efficient preparations by market participants and may exacerbate negative
perceptions in the marketplace. Financial institutions should share information in order to
strengthen confidence that the Year 2000 challenges are being met in all financial sectors
worldwide. In February 1999, the FFIEC issued guidance to financial institutions on how to
address customer expectations. It emphasizes that maintaining customer confidence in the
financial services industry now and after the Year 2000 needs to be a top priority of the institution
and its senior management.
In 1999, our outreach program will focus on business resumption activities, including Year 2000
risk mitigation and contingency response actions. The first outreach program occurred in
December 1998, when officials from the Federal Reserve presented, via videoconference, an
interactive session with its depository institution customers on the Federal Reserve's contingency
planning for the Year 2000.
Banks are urging their regulators and other government officials to promote public confidence by
speaking clearly and forcefully about Year 2000 preparedness. Regulators can play a constructive
role in making sure that Year 2000 information disseminated to the public is factually accurate,
balanced, and broadly distributed. Communications are a shared responsibility. Research tells us
that customers want to hear directly from their bank and that the public is interested in specifics,
not generalities, about our preparations. The Federal Reserve is expanding its program of
outreach, with every Reserve Bank working on an aggressive program of local communications. I
urge you to do the same. The public needs to know that the Year 2000 is like other challenges we
have met through careful preparation, risk reduction, and contingency planning to allow us to
work around any problems that might occur.
Public Obligations and Patterns of Behavior
As we get closer to the century date change, there will no doubt be more sensational coverage in
the media. It is our obligation to be smart consumers of information and to listen to responsible,
not alarmist, voices. Remember, as with anything that has a degree of uncertainty, there will
always be those who predict the most dire outcomes. They have generally been wrong in the past,
and I expect that they will be wrong again. There are likely to be some disruptions from the
century date change; nothing this large and complex can be perfectly faultless. We should
remember, however, that there have been serious disruptions to service in daily life before, from
storms, temporary power outages, disruptions of telephone service, etc. In general, these prove to
be annoying and inconvenient, but nothing more.
We also need to maintain reasonable and responsible patterns of behavior. It is possible that
market participants may reduce clearing and settlement activity on December 31 and January 3.
Several participants, however, have indicated plans to reduce activity over a substantially longer
period, up to a month. While such a reduction may appear to be prudent to an individual firm,
such action by multiple participants raises the possibility of thin markets with accompanying
erratic price behavior. Our perspective has been to encourage market participants, especially
those who hold themselves out as intermediaries, to consider carefully the overall implications,
including for market liquidity, of reductions in trading volume so that risks and benefits of such
initiatives are appropriately balanced.
I understand that some organizations that normally make payroll or other payments using the
ACH are thinking about whether they should make these payments by cheque in the days
immediately following the rollover to the Year 2000 as part of their contingency planning. I hope
these organizations carefully consider all of the implications of such a step before making a final
decision in this regard. We have a high degree of confidence in the ability of the Federal Reserve
and the banking industry to continue to process electronic payments during this period. The
drawbacks to the payment recipients of this change to business-as-usual practices may well
outweigh any perceived benefits.
Conclusion
I believe that the financial services industry has made great progress in addressing Year 2000
issues. During this next year you will not only need to do your best to continue to repair and test
your own systems, but will also need to evaluate the risk of potential failures and the effect of
these failures on your business. Further, you will need to test fallback procedures or work-around
processes that mitigate the effect of such failures on your ability to continue to conduct business.
Finally, we must continue to be a reliable source of accurate and sound information to maintain
the public's trust. I do not doubt that we can collectively rise to these challenges.