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Paul M. Connolly, First Vice President and Chief Operating
Officer, Federal Reserve Bank of Boston
Boston, Massachusetts
January 14, 1999
I appreciate this opportunity
to speak at the NICSA regional meeting. And I am happy
to say that this is a continuation of collaborative
work between NICSA and the Federal Reserve Bank of Boston
which we have had under way for several years. Since
the early 1990's we have participated in the meetings
and the work of your Custody Fund Accounting Administration
Committee, or CFA Committee. In fact, for a few years
now my Bank has hosted an annual planning meeting for
the Committee, and some of our experts with Total Quality
Management techniques have helped the Committee to develop
its priorities for the year ahead. We also have spoken
several times at NICSA regional meetings, here and around
the country, about electronic payment systems, and depositories
for securities. These activities have given our Bank
a valuable window on the world of mutual funds and the
banks and other organizations which work with them.
This kind of information can help us to identify market-oriented
improvements for some of our most important services
for the banking industry, such as the Fedwire Funds
Transfer System and the Bookentry Securities Transfer
System. In turn, we hope we are providing information,
as well as advocacy, to intensify your interest in using
electronic payments in place of paper checks, so that
you and your customers can benefit from a better national
payments system. We look forward to continuing to collaborate
with NICSA, and I hope this discussion will be another
helpful contribution.
My subject
is preparing for the year 2000, a concern which all
of us have in common. I would like to offer you some
thoughts on the possible economic effects of the coming
of the year 2000, or Y2K. Also, I will give you a brief
overview of the outlook for the banking industry as
it prepares for the year 2000. I would like to share
with you some of the important steps we in the Federal
Reserve are taking, nationally as well as here in New
England, to prepare operationally for Y2K. And then
I would like to mention a few issues which require ongoing
attention from all of us. In particular, I believe we
all can make important contributions to public confidence
and the avoidance of needless panic by becoming more
active during 1999 in sharing all of the facts about
our preparations for Y2K with our customers and the
broader public.
Since
most enterprises in America have to do some work to
get ready for Y2K, it is impossible to know exactly
what it all will cost. During 1998 the Federal Reserve
Board developed an estimate, based on corporate reports
to the SEC, that the U.S. private sector would spend
roughly $50 billion dollars, and quite possibly more,
to renovate and test systems for the year 2000. As you
know, public companies have been reporting about their
Y2K preparations in their 10K reports since the third
quarter of 1998. Here again, it is difficult to get
a complete and clear picture, but it seems likely that
many organizations will wind up spending more than they
thought previously to complete their preparations. In
addition to these private sector costs, the Congress
has budgeted about $6 billion dollars for Year 2000
preparation by the federal government. There is no comprehensive
information available about state and local governments,
but probably some billions more will be spent in these
areas. Worldwide, the Gartner Group has estimated that
the costs to get ready for the Year 2000 will run between
$300 and $600 billion dollars.
All
of this spending will have both positive and negative
effects on the U.S. economy. Overall, the net impact
is likely to be at least slightly negative. The biggest
impact may be the opportunity costs of Y2K. When we
commit so many of our scarce IT resources to renovation
of systems, we have to sacrifice at least some innovations
we would be pursuing to make processes more efficient,
or to build better mousetraps which would increase revenues
and profits. We must be losing, or at least deferring,
initiatives which would boost productivity and help
businesses to continue to offset rising labor costs
with productivity gains.
As an
estimate, the net effect of Y2K spending could be a
reduction in the growth of U.S. labor productivity by
1 or 2 tenths of a point in 1999 and in 2000. The overall
gross domestic product might grow by about 1 tenth of
a point less than it would have otherwise in each of
these two years.
It is
difficult to sort out exactly how Y2K will affect the
economy, because some remediation efforts actually will
introduce new, more efficient systems to replace non-compliant
older systems. Smaller enterprises seem to be more likely
than larger ones to use replacements as their direction
to prepare for Y2K. Many larger organizations apparently
find their legacy systems too complex to replace in
the relatively short time they have set aside to get
ready for the Year 2000.
We can
anticipate something of an inventory cycle due to Y2K.
Manufacturers and others may build inventories in late
1999 to guard against shortages of raw materials, inputs
to production, and goods for sale. These higher inventories
then would be run down in early 2000.
No doubt
you have heard some talk about a recession in 2000,
to be brought about by Y2K. Of course nobody can say
that that is impossible, and I respect the professional
economists who make that forecast. However, we in the
Federal Reserve believe that that outcome from Y2K is
very unlikely. At the time of the Year 2000 rollover,
probably there will be some production and distribution
problems, and some problems with public services and
utilities. We have had such problems in the past, and
we have worked through them and returned to normal business
operations. If these outages are short-lived, they should
not have any lasting effects on the overall economy.
Problems which were more widespread and lasted much
longer could have feedback effects which could hurt
the overall economy, but while that cannot be ruled
out, it is not our expectation; particularly if all
of us do what we should do now to prepare for the Y2K
event.
One
other likely development to bear in mind: I anticipate
some considerable pent- up demand in 2000 and 2001 for
IT resources to build those better mousetraps that have
been put off in 1998 and 1999. Many businesses that
are seeing a bulge in their IT costs now because of
Y2K preparations may be expecting big cost reductions
after January, 2000, but may not get them.
I'd
like to tell you a little bit about what the Federal
Reserve and other bank regulators have been doing to
work with the banking industry on its preparations for
Y2K. In a coordinated effort with the other banking
regulatory agencies, the Federal Reserve is working
closely with the institutions it supervises. Results
to date indicate that banks continue to make good progress
in meeting their Year 2000 objectives. Like all of us,
the banks still have a lot of critically important work
to do, and must keep up their very good efforts throughout
1999.
Our
supervisory reviews of the banks have been divided into
two phases. Phase One, which ended on June 30, emphasized
awareness, assessment, and renovation of the banks'
mission-critical systems. In this phase the Federal
Reserve itself reviewed more than 1,600 institutions
nationwide. Of course the other bank supervisors, such
as the FDIC and the Comptroller of the Currency, reviewed
thousands more. Our reviews showed that the overwhelming
majority of institutions had made satisfactory progress
in their planning and readiness efforts.
The
second phase began on July 1, and will continue through
March 31 of this year. This phase will emphasize renovation,
testing, and implementation of those mission-critical
systems. During these 9 months, the Federal Reserve
and the other agencies will conduct another round of
reviews.
We do
anticipate that in this second phase of reviews we may
find somewhat more banks have fallen behind in meeting
their Y2K milestones, because the tasks they must undertake
in this phase are more complex. Overall, though, most
banks, large and small, across the country have been
making good progress, and if they continue to work as
effectively in 1999 as they did during the past couple
of years, we as customers can expect to have our banking
services available as usual come January, 2000.
As a
banking regulator, we are devoting many people and a
great deal of time to monitoring the banking industry's
preparations for the Year 2000. As a bank, and as a
provider of vitally important services to depository
institutions, we also are devoting many people and a
great deal of time to ensuring that our own systems
are renovated and tested extensively in advance of the
Year 2000. We really have worked hard on this for a
long time, so that now nearly all of our mission-critical
systems are compliant, and our internal testing is nearly
complete. Specifically, we have 105 mission-critical
systems nationally. Of these, 99 now are complaint and
the remaining 6 will be replaced by March. Furthermore,
we expect to have all of our non-critical systems taken
care of before the middle of this year. Our mission-critical
systems include some that your organizations rely upon
every day, such as Fedwire Funds Transfer, Bookentry,
the Automated Clearing House, or ACH, and the Reserve
Accounting System used by your banks.
At the
heart of our preparations for Y2K is testing our electronic
interfaces with depository institutions using those
important systems. We set a target to have all of these
applications ready for testing by July 1, 1998, to give
our customers lots of time and many opportunities to
test with us. We hit that target. Since July 1 all of
these payment and information systems have been available
for testing with all twelve Reserve Banks.
Nationally,
over 10,000 institutions of all sizes maintain nearly
12,000 electronic connections with the Federal Reserve.
One institution may use its electronic connections for
as many as 15 applications. Testing so many applications
with so many institutions nationwide is no easy task,
but we have made substantial progress already. Here
in New England, the Boston Reserve Bank has electronic
connections with about 480 institutions. Nearly 400
of them already have done some testing with us. Others
are scheduled for testing soon. Nationally, we have
had about 6,000 institutions conduct more than 120 thousand
tests with us.
Both
nationally and locally this Y2K testing has been going
quite well. Our Federal Reserve applications with their
renovations for Y2K are working, and our customers appear
to be interfacing with them well. We still have a lot
of testing to do, but so far, so good. And this testing
with the Federal Reserve is another indicator that the
banking industry is preparing well for the Year 2000.
A lot
of our work on Y2K during 1999 will focus on our contingency
planning. I would like to describe for you how we are
approaching contingency planning, not with any idea
that our way is the best way, but with the thought that
you might pick up something from our approach that would
help your own organizations.
There
are six major stages in our contingency planning. First,
the best kind of contingency planning is to do everything
possible to make sure you will not have to fall back
upon contingency plans. For the resources under our
own control, including not just our own software applications
and computers, but also our building systems and so
forth, we have undertaken a very thorough effort, as
I have suggested, to renovate, test, and certify that
these systems are expected to work reliably in January
2000. The better the job we do at this, the more likely
it is that we will not have to fall back upon contingency
plans to keep our critical systems going. We might say
in this regard that the best defense is a good offense,
for you and for us.
Second,
extensive testing with those who are connected electronically
with us is an essential measure. And as I have reported
to you, we have put a lot of emphasis on testing with
our customers, to good effect. Again, the more extensively
you and we have tested the systems which connect us
with other parties, the more confidence we can have
that they will continue to serve us well in 2000.
Recognizing
that things can go wrong, either with those resources
under our control or with those external resources we
do not control, such as utilities, our third phase of
preparation is the development of what we call business
resumption plans, which describe what we will do if
a disruption occurs. We start with the lessons we have
learned from the past: that is, the contingency plans
that Reserve Banks have developed and updated over the
years as we experienced other kinds of operational disruptions.
We have learned how to keep our critical systems going
in the face of disruptions from blizzards, earthquakes,
and floods, and we have developed backup arrangements
when our buildings lose electricity or other utilities.
We are
augmenting these plans to reflect the unique risks of
Y2K, which makes it at least a little more likely that
some disruptions might occur, and also makes it more
likely that any such disruptions will be more widespread
than they might have been at other times.
As a
fourth phase of contingency preparation, we are using
a set of Y2K scenarios to test our contingency plans,
identify any gaps, and then improve the plans. In this
regard, we intend to focus on a fairly small number
of critical scenarios in great depth, and perhaps use
some additional scenarios to make sure our plans have
not missed anything crucial. Some of you already may
have found, to your frustration, that the list of possible
problems you can worry about seems endless. However,
the use of a limited number of potentially critical
scenarios, that would have severe effects on our major
business areas, will help us to develop the most effective
contingency plans possible.
A key
consideration, I think, in deciding what scenarios to
use to test contingency plans is to make sure that the
scenarios will test every major business area in the
organization. For instance, a scenario about disruptions
in utility services to a Reserve Bank affects all business
areas, but our building operations and automation people
would see themselves as our first line of defense, to
respond to such problems, and would be able to test
their contingency plans in considerable detail against
such a scenario. Meanwhile, another scenario, about
possible liquidity problems in the banking system, also
would affect all of our business areas, but in this
case our discount window and monetary policy business
areas would see themselves as our first line of defense
and would test their plans in great depth against such
a scenario. Your institution will have its own best
sense of the possible disruptions that would have the
greatest impact on you, and you can develop scenarios
and test contingency plans accordingly.
Fifth, we will be testing our contingency plans during
the first months of 1999. A contingency plan is just words
on paper unless it has been tested, and then improved
and adjusted in light of the testing. It might be easy
to overlook this step, but please keep it in the forefront
of your plan.
Sixth,
we will need well-thought-out event management plans
for the actual transition, that is, in late December
1999 and early January 2000. Rather than try to have
an advance plan for every possible development, we must
have plans and people and decision-making criteria in
place to enable us to respond rapidly and effectively
to whatever develops. To help with our event management,
and identify problems as early as possible, we will
have people in the Bank at 12 midnight, as the new Waterford
crystal ball is dropping in Times Square, to see how
our telecommunications and our incoming utilities and
our internal building systems hold up at the moment
when Year 2000 arrives. Then, during the day on January
1, people in all of our departments will come in to
test our automated systems, well ahead of the first
business day on January 3. In these ways and many others
we will focus on managing the Y2K event.
The
final area I want to touch upon with you this evening
involves a few issues which require the attention of
all of us.
First,
utilities, such as electrical power and telecommunications.
Some of you know that obtaining information about the
preparations of utility companies for Y2K was difficult
during much of 1998. More recently, though, I have seen
some evidence that utilities have a greater appreciation
for the importance of sharing with their customers more
information about Y2K. Actually, many utilities may
be further along than you realize, and at the national
level some of the major players have plans for integrated
testing of their systems during 1999. Nevertheless,
every utility company has its own story, just as every
bank or every mutual fund has its own story. As customers
of these companies, we need to know where they are in
their preparations. The only way to find out is to ask
the companies with whom each of us does business. We
should be willing to share with them any information
about our preparations which could be useful to them,
and then we need to ask for as much information from
them as we need to gain confidence that they are on
track for continuing to serve our needs reliably in
2000. This could be an activity which a number of us
using a common service provider could enter into together.
One
of the most difficult sectors on which to obtain good
Y2k information is local government around the country.
Here also we need to go out and ask them what they are
doing to prepare for Y2K. Think, for instance, of how
water gets into your building. It is delivered by some
combination of state and local governmental units. Think
how quickly you could be put out of business if no water
were coming into your building. In a good number of
cities and towns your electricity is delivered into
your buildings by local government. It would make sense
for a group of businesses in the same city or town to
get together with their local government officials and
share information about Y2K readiness.
The
amount of information available about international
preparations for Y2K varies widely by country. Here
also people in the United States feel considerable uncertainty.
For the banking systems of the European countries we
can take some comfort from the rather smooth introduction
of the Euro on January 1. More broadly, though, it still
is hard to get an overall sense of Y2K readiness. And
in fact, there probably cannot be any one overall sense,
because conditions will vary by country.
The
Federal Reserve is leading a group called The Joint
Year 2000 Council, which brings together many financial
regulators from around the world. This Council is working
to improve communications and the sharing of information
about Year 2000 issues. We also are working with a private
sector group known as the Global 2000 Coordinating Group,
or G-2000. This group includes more than 40 large financial
institutions from over 20 countries. G-2000 has developed
a standard framework for assessing a country's preparations
for Y2K, and these assessments are going on now.
Those
of you with investment activity, and clearing and settlement
arrangements, in other countries may know more about
the state of readiness of those countries than anyone
else knows. If you have mechanisms you can use to share
information with others in your industry, I hope you
will do so for the common good. You also may be thinking
about ideas to minimize risk during the critical last
days of 1999 and first days of 2000. For instance, you
may be able to set contractual terms that would reduce
the number of transactions to be settled during those
critical days.
One
issue that has already received a great deal of attention
is the potential demand for cash. Probably you have
heard or read that people will want to hold more cash
as they anticipate the coming of January 1 and the possibility
that they will not be able to get at their bank accounts
or use their ATM cards. In fact, this is not an issue
just for banks. As you know well, many people now think
of their mutual funds, and in particular their money
market accounts, as their bank accounts. I wonder whether
you are giving attention to the prospect that some of
your customers could be requesting unusual withdrawals
during December, just as other consumers will be withdrawing
cash from their banks. Even insurance companies have
some reason for concern here. One of the largest companies
told me recently that it is preparing for the possibility
that a larger than normal number of customers may seek
loans against their insurance policies to increase their
cash liquidity.
Well,
first let me assure you that there will be plenty of
cash available. Then, let's think about what we can
do to give consumers enough assurance about banking
services and mutual fund services that they will not
feel the need to hold large amounts of cash.
As a
precautionary measure, the Federal Reserve plans to
increase the amount of currency either in circulation
or in our vaults to meet the public's demand. The value
of the currency in circulation in July of 1998 was 460
billion dollars. In late 1999 we plan to have about
700 billion dollars either in circulation or in the
vaults of the Federal Reserve and the Treasury. This
will provide a good-sized cushion to meet increased
demand. Also, we will take steps to ensure that depository
institutions will be able to obtain currency from us
on a timely basis to meet the needs of their customers.
The depository institutions should be ordering their
cash from us before the last part of December, and we
will work with them to get that done. We also will be
prepared to work extra hours in our cash departments
at all Reserve Banks to meet demand.
The
real issue here, though, is why many consumers might
want to hold extra cash. It could very well make sense
to have a little extra cash on hand over the New Year's
holiday weekend, just to be sure we can buy groceries,
and gas, and other daily necessities. In my own opinion,
it would not make any sense to hold large amounts of
cash at home rather than in insured bank deposits or
in interest-earning mutual funds. The only reason large
numbers of people would consider doing so is that they
do not have confidence that their banking and investment
services will continue to be reliable and accessible
in January 2000.
All
of us have an interest and an obligation to maintain
public confidence in our nation's financial system.
People should not be exposing their savings to the risks
of loss or theft because they have heard scary stories
about Y2K, and have not heard the other side of the
story from their banks, their mutual funds, their insurance
companies, and the other organizations on which they
have relied for many years.
You
know all the steps you are taking to make your systems
reliable and to remain in business come January, 2000.
You may not yet have shared all of this information
with your customers. The more facts you can provide
to them, the more you will be helping them to make rational
decisions about their money.
As we
go through 1999 all of us must pay more attention to
the importance of providing more factual reassurance
to everyone with whom we do business, and to everyone
who relies on us. The better prepared all of us are,
and the more information all of us share, the more likely
it will be that we will make it safely through the century
date change and keep making progress in the Year 2000.
Thank
you.
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