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Cathy E. Minehan, President and Chief Executive Officer,
Federal Reserve Bank of Boston
The Boston Economic Club
March 17, 1999
Let
me take you forward 289 days and about 11 hours from
now. It's 11:59 on December 31, 1999, and instead of
being sensibly home in bed, or out ringing in the new
millennium, your chief technology officer, and perhaps
even you yourself, are sitting in the central control
room of your financial services firm. The atmosphere
is hushed, and as the clock ticks out the seconds to
midnight not a sound is heard around the room. Everyone
is holding his or her breath awaiting the big moment
when midnight comes, and everything moves into Y2K mode.
The
preparations for this moment probably began at your
firm as much as a year or two ago. They have involved
thousands of hours of investigating where and how dates
are used in your firm's computer systems; renovating
code and testing, and have absorbed millions of your
firm's dollars. It's Friday night, and many of the world's
major markets (the U.K., Germany, and Japan) were closed
during the day, and will be closed Monday as well because
of traditional holidays, giving you Saturday and Sunday
to test and a relatively quiet Monday as well. You realize
that transaction volumes may well be greater on Tuesday
as a result, but your firm has also engaged in efforts
to reduce the volume of business that needs to settle
around the date change. You've tried to foresee important
contingencies, tested with major customers, and stayed
abreast of local utility and infrastructure efforts
to be Y2K compliant, and, if you are a bank, filed all
the forms to borrow from the Federal Reserve Bank of
Boston if necessary. Yet you are holding your breath
as well, realizing that Y2K problems anywhere in the
complex and increasingly integrated world of global
finance could quickly become yours. What will happen?
I am
becoming increasingly confident that as it regards the
U.S. financial world, and the variety of systems that
support it, the answer to that question is clear. Not
much will happen. I want to focus my comments today
on why I have this level of confidence, and what I believe
some of the remaining issues are.
First,
a quick definition of the problem. The Y2K problem started
as a short-term solution to the high cost of computer
memory in the 1950s and '60s. One report on the year
2000 challenge notes that in the early '60s, core memory
for an IBM computer cost about $1 per byte; today's
semiconductor memory costs around $1 per million bytes.
Thus, there was a very strong economic incentive to
minimize the amount of memory needed to store a program
and its data in the computer's memory.
This
problem was addressed by using only the last two digits
of a 4-digit date in the record—68 for 1968, for example.
This became the convention, and, until quite recently,
this short-cut was used even when systems were completely
redesigned and memory costs were lower. The problem
posed by the short-cut is simple and was always well-known—after
December 31, 1999 two-digit dates could mean dates in
either of two different centuries and cause errors of
uncertain proportion. However, a concerted effort to
address this problem was not made. Most enterprises
given the choice between developing new products and
services or fixing computer programs that could wait
a while longer made the obvious choice. Thus, the two-digit
standard for representing years continued much longer
than anyone would have anticipated.
Now,
however, we no longer have the luxury of time. The Y2K
short-cut has to be eliminated, and it is not proving
easy or cheap to do so. Estimates of the costs involved
both nationally and worldwide vary considerably, especially
when the potential for litigation and damages is considered.
The Gartner Group estimates about $600 billion will
be spent worldwide, but that does not include litigation
and damage costs. Another estimate--that of Capers Jones
Software Productivity Research in Burlington, Massachusetts—is
$1.6 trillion including litigation and damages. Obviously
the vast majority of those costs will be incurred by
the developed countries, and within that amount, the
U.S. will likely bear the lion's share.
Indeed
one of the enduring lessons of Y2K applies to almost
all "short cuts" in operations or technology—pay me
now, or pay me more, much more, later. This problem
should have been fixed with each software redesign but
it wasn't and now the cost of doing so looms large.
That
said, how are we doing? I think we're doing pretty well.
That's based on extensive oversight of our efforts within
the Federal Reserve System to make our own systems Y2K
compliant, to test our connections with 12,000 depository
institutions around the country, and our supervisory
oversight of those institutions. Moreover, my sense
of confidence is also buoyed by surveys and assessments
done by J.P. Morgan, the Special Senate Committee on
the Year 2000 Technology Problem, and the President's
Council on Year 2000 Conversion, all released during
this first quarter of 1999. I want to share some specifics
on industry readiness with you from these various sources.
But first, a couple of additional thoughts.
One
of the key factors in my level of confidence in the
financial industry's readiness for Y2K lies in the fact
that the industry as a whole has an impressive record
of coping with operational challenges. From blizzards
to power outages to major software failures, the industry
has coped, learned from its errors, built sophisticated
and expensive back-up capabilities, and gone on to create
a record of virtually error-free operation. The industry
knows how to solve problems when they occur, and how
to resume operations as quickly as possible.
And
we're already gaining expertise in analyzing and fixing
Y2K problems. For example, credit card expiration dates
after 2000 when first encountered could not be processed—now
they can. According to a Price Waterhouse Coopers study,
during 1998 Y2K problems caused travel agents difficulty
with advanced bookings; automatic inventory order systems
halted in some cases, and in some systems, leases, securities,
and other orders could not be processed. All of these
problems have now been resolved. As the J. P. Morgan
study puts it, "the real Y2K effect on society and the
economy has been spread across a much wider spectrum
of time and is of a much more subtle form then the overnight
chaos predicted by Y2K doomsday experts. Y2K problems
have been occurring, continue to occur, will occur on
January 1, 2000, and will continue to occur throughout
2000 and into 2001 ". Indeed, Gartner Group expects
that only about 8% of Y2K affected code will actually
be at issue on January 1, 2000.
Second,
its one thing for me—a knowledgeable insider—or any
of you seasoned financial professionals—to be confident
of success. Its quite another to have broad-based public
confidence. Such confidence is critically necessary
if people are to avoid doing things that are inherently
more risky than anything Y2K might present—like drawing
all their savings out of banks or mutual funds. Communication
of the solid progress being made is key here, and I'll
speak more to that later.
Finally,
glitches will certainly occur, maybe even large ones.
But with adequate contingency planning and event management,
glitches can be contained. I'll talk a little bit about
contingency planning and event management later as well.
But first, let me bring you up to date on the readiness
of the financial services industry as I see it.
When
I think about Y2K readiness I often draw the analogy
of throwing a rock into a still pool of water. You can
control the speed of the throw and the trajectory and
thus the height of the splash of water made by the stone.
But you cannot control the ripples of water in concentric
circles around the entry point of the stone. And the
further away from that entry point, the fainter and
less complete the ripples seem. Using this analogy,
I think of the Federal Reserve's own efforts as the
splash; I know a lot about them and feel largely in
control. The closer ripples—those efforts of entities
closely tied to the Federal Reserve like depository
institutions—are more sharply delineated. I have great
confidence in their readiness as well. The farthest
out ripples—efforts in other countries—are clearly harder
to know about, and information about some is fuzzy.
The
splash and ripple analogy highlights the responsibility
every organization has to be responsible first for the
Y2K readiness of its own systems. If this job is done
well and extensive tests are conducted with business
partners, the "big picture" of overall readiness will
be addressed. This is clearly true in the case of Reserve
Banks which play a special role in the settlement of
financial markets. Each day over $2 trillion passes
through Reserve Bank books representing the settlement
of the U.S. Government securities market, the Eurodollar
market, the dollar leg of all other foreign exchange
transactions, settlement for a wide variety of security
and bond markets, about 66 million checks and 16 million
ACH payments, among other things. Without functioning
Reserve Bank systems, much of everything else in the
U.S. financial world comes to a halt. Thus, Federal
Reserve concern from the beginning has been that our
systems and those of depository institutions be Year
2000 ready as soon as possible.
Reserve
Banks began Y2K project efforts more than two years
ago. By the middle of 1998, all of the systems Banks
use to interface electronically with depository institutions
had been made Y2K compliant and were ready for testing
with customers. By early this year, nearly all systems,
both external and internal were fixed and tested, and
those systems are now in production. This means that
the systems that Reserve Banks use in the provision
of financial services today are Y2K compliant. These
systems function today exactly as they will in the new
century.
Moreover,
these are the same systems that are being used in test
mode with depository institutions; thus they are also
being stressed continually with the variety of test
scenarios used by those institutions. About 8,000 of
the 12,000 depository institutions that connect electronically
with Reserve Banks, including virtually all major banks,
have tested their connections with us, and all users
of Fedwire funds transfer will be required to do so.
These tests have been going well. The impact on staff
time in both Reserve Banks and depository institutions
has been considerable, but this kind of testing with
business partners is essential for Y2K preparedness.
Recognizing that nothing in life can be fully guaranteed,
I am as confident that Reserve Bank systems and their
customer connections will function without fail in the
new century as I am that they will function this afternoon.
The splash in the pond is well under control.
What
about the first ripple—the depository institutions that
connect with Reserve Banks electronically, and other
financial institutions? The Federal Reserve and the
other federal banking agencies have been working hard
to examine every federally insured depository institution
in the country for Y2K readiness—not just once but several
times.
The
banking agencies have established objective milestone
dates for completing all phases of Year 2000 preparations,
from the inventory of systems for Y2K problems and development
of plans to replace those systems, to remediation and
testing—the areas we are examining at banks right now—to
the implementation of Y2K compliant systems and completion
of contingency plans by June 30 of this year. We have
found that banks are making excellent progress in meeting
these milestone dates, with close to 97 percent of all
banks making satisfactory progress. We are requiring
banks to assess customer and counter party risk and
take steps to mitigate those risks, and we are overseeing
major service providers and software vendors as well.
What
about financial services firms beyond commercial banks?
Much is being done there as well. Major securities firms
actually began Y2K efforts somewhat before the banking
industry and have successfully conducted at least two
extensive end-to-end street-wide tests. Smaller broker
dealers and registered investment companies were thought
by the SEC to be somewhat behind the larger firms last
September, with only about 30 percent of their efforts
completed. However, six months have passed since then,
and many of these firms were able to participate in
the recent industry-wide test, so there is reason to
be confident progress is being made. We've brought insurance
and mutual fund companies in the First District together
here at this Bank, and their comments on their own,
and their industry's readiness were reassuring. All
states have initiated a survey or examination effort
for domestic insurance companies, and June 30, 1999
has been established as the date by which mission-critical
systems should be Y2K compliant. For both banks and
other types of financial service firms, the impact of
counterparty readiness is clearly significant. For those
firms with a domestic business concentration, I believe
risks have been reduced substantially. Firms with a
large foreign presence obviously face greater risks,
which I'll speak to a little more later.
Moving
to the next ripple, what is known about financial utilities,
such as stock exchanges, clearing houses and the like?
In September 1998, the SEC reported that for the eight
national securities exchanges and for the NASD, 95 percent
of critical system coding and testing was complete,
and Y2K compliant systems were being put into production.
For the nine registered or exempt clearing agencies,
about 90 percent of code change testing had been completed,
and about that percentage of systems had been implemented.
Surveys done in the first quarter of 1999 indicated
that these systems will achieve Y2K compliant operations
well in advance of the new century.
None
of us will function very well without the variety of
public utilities—power, water, transportation and telecommunications—that
make modern life possible. Indeed, the dependence of
the financial sector on various utilities, especially
power and telecommunications has been recognized by
those charged with national Y2K coordination—The Presidents
Council. The Council's financial sector workgroup, chaired
by the Federal Reserve, works closely with utilities
to ensure problems are addressed and priorities are
clear. Reliable utility operations are expected especially
from major vendors, but less is known about small carriers
and services in small communities and rural areas. Just
to make the scope of the issue a little clearer, there
are 3,200 electric utility companies in the United States,
and about 60,000 community public water systems. Problems
affecting particular areas are possible, if not probable,
but much effort is underway to ensure they do not occur.
Officials
from this Bank met recently with suppliers of power
to New England. We were told that steps are being taken
not only to make those suppliers' systems compliant,
but also to insulate New England from failures elsewhere
more fully than it is today. In a sense, then, we may
be more protected from power failure during the century
changeover than we are currently. Similarly, much has
been made about the potential for transportation difficulties.
According to the President's Council on the Year 2000,
air carriers, larger airports and transit providers
are making significant Y2K progress, but there is concern
about airport and transit services in small communities
and rural areas.
Moving
to the next ripple, U.S. Government agencies have been
seen as challenged in several reports, and some are
thought to be behind schedule in fixing some mission-critical
systems. However, those systems that most directly affect
the financial world—those in the Treasury and Social
Security—seem to us to be in good shape. Social Security
systems are renovated and tested, and are now fully
in production in Y2K mode. Reserve Banks have been asked
to run end-to-end tests with social security files,
ensuring operation is problem free from the inception
of the file to the posting of social security payments
to recipient accounts. Clearly this would be a useful
test, and we are exploring ways it might be conducted.
Finally,
the last ripple—the one that is less clear in its resolution—is
the state of foreign entities, financial firms and governments.
Here the various report results are mixed and data is
more limited. In general, foreign entities are seen
to be behind their U.S. counterparts in both the private
and public sectors. Gartner reports that the U.K. and
Scandinavia are on a par with the U.S., while Germany
and Latin America are further behind. Not surprisingly,
developing countries are seen to be behind the developed
world.
Considerable
effort is being made to bring this ripple into better
resolution. Roger Ferguson, one of the Governors on
the Federal Reserve Board, chairs an international group
known as the Joint Year 2000 Council. This council of
central bankers, bank supervisors, and insurance and
securities regulators has sought information from bodies
in 170 countries. The council shares information on
Y2K regulatory and supervisory strategies and acts as
a point of contact with national and international private
sector initiatives. It has established a committee to
share information with international entities such as
the IMF, VISA, SWIFT, Euroclear and Cedel. In addition,
a totally private sector group known as the Global 2000
Coordinating Group has been formed to coordinate initiatives
related to Y2K in the global financial community. Both
the Joint 2000 Council and the Global 2000 Group have
assessed readiness in a variety of markets, conducted
surveys and encouraged readiness in a variety of ways.
But the degree of penetration here remains a question.
On an
optimistic note, I view the relatively glitch-free implementation
of the Euro in January as an indication that at least
Europe is likely to be ready for Y2K. A number of systems
in some institutions were made Y2K compliant when the
changes needed for the Euro were made. More importantly,
institutions demonstrated the ability to meet a time
bound, technologically complicated deadline albeit one
with a more narrow impact. In my view this augurs well
for Y2K, but clearly risks are higher in the foreign
arena.
In sum,
then, Reserve Bank assessments, and reports and surveys
done by others on the state of Y2K readiness all point
in the same direction. The financial sector—especially
domestically—and the needed utilities that support it—are
highly likely to succeed in making a smooth transition
to the new century. Risks remain—most clearly in the
foreign sector—and glitches are inevitable, but with
every passing day the likelihood of success is greater.
That
likelihood of success should not lull us into a false
sense of security. In order for it to be achieved, we
must continue to make progress and that requires continued
work, testing, and attention. Moreover, it also requires
that contingency scenarios and the need for managing
operations and communications around critical periods—so
called "event" management—be addressed.
From
a contingency perspective, much Reserve Bank attention
has been devoted to the matter of liquidity—for individuals
in the form of cash, and adequate funding for financial
institutions. While the nation's major ATMs are generally
compliant now, and the likelihood of bank problems is
small, we have recognized the public may choose to hold
more cash as a precautionary measure. To address that,
Reserve Banks will have extra cash to increase the amount
in circulation. Based on normal growth, U.S. currency
in circulation should increase from $460 billion in
mid 1998 to close to $500 billion by late 1999. About
two-thirds of that is held in foreign countries, so
about $170 billion will be in circulation in the United
States at year-end. In addition, Reserve Bank vaults
hold about $150 billion in reserve. That amount will
be increased by $50 billion by late 1999 simply as a
Y2K precautionary measure. That means Reserve Banks
will have sufficient currency in reserve to more than
double the amount in circulation domestically, in the
highly unlikely event that this is necessary. One remaining
issue that we're working hard on is how to ensure that
this large amount of valuable paper is where it is needed,
rapidly and securely.
Liquidity
issues for financial institutions can take two forms—too
much, and too little. Many institutions have focused
their contingency planning on assessing counterparty
readiness, and developing plans to limit both the amount
of business that will need to settle at year-end, and
where and with whom it will settle. Roll-overs may be
avoided, leaving some institutions with swelling balance
sheets. On the other hand, problems may disrupt normal
funding patterns creating shortages for other institutions.
Overnight funds markets could be strained in the equilibrating
process, leaving some firms flush at settlement, and
others in deficit. Reserve Banks have made it clear
that they will stand ready to lend in appropriate circumstances
to depository institutions, and an extensive outreach
effort has been launched to help institutions get the
paperwork and collateral ready. In addition, the normal
tools used to absorb excess liquidity by the Open Market
Desk will be available to deal with soft funds markets.
Event
management, and the handling of contingencies, are tightly
linked. As we see it, addressing matters that occur
during key time periods during the century date change
will be critical to maintaining public confidence. That
puts the emphasis on good communications, on being proactive
about seeking information on the status of critical
counterparties, and on quick problem resolution. These
are matters that are absorbing a lot of Reserve Bank
attention right now. We don't have any magic bullets
here, but we are stepping through both how all our offices
communicate with each other and with the wider world,
and establishing appropriate protocols for addressing
and resolving problems.
Finally,
let me leave you with a few more Y2K related thoughts.
First, despite all my reassuring words, and all the
work that has been and will be put into this effort,
something can and will go wrong. However, the impact
of problems, even large ones, will vary depending on
public perception. On one end of the spectrum, the failure
of one ATM could cause a crisis if people are nervous
enough; on the other end, the stoicism that gets us
through snowstorms and other calamities will be the
reaction if people are calm. The key to public confidence
increasingly is communication. Most, if not all of the
nations' banks, financial firms, utilities—you name
it—have good, reassuring stories to tell. However, many
firms have been heeding their lawyer's advice and saying
nothing for fear that unavoidable problems may occur.
A bit of legislative relief from the potential for litigation
occurred last fall with the passage of the Year 2000
Information and Readiness Disclosure Act. Even with
this help, the complexities of Y2K can make it hard
for firms to speak clearly. But speak clearly they must,
for now is the time to convey messages of confidence.
Second,
I think the likelihood of economic demise as a result
of Y2K is remote. Based on past experience, and the
knowledge rapidly piling up on Y2K readiness, the inevitable
problems are more likely to be of short duration, and
affecting limited areas than they are to cause widespread,
extended disruptions. While there is a potential for
mild inventory building in late 1999, and then a reversal
in early 2000, the effects of this will likely be small
and hard to sort out from the usual quarterly volatility.
Moreover, if Reserve Banks are any indication, there
won't even be a steep drop in the need for technology
support or equipment. We have enormous pent-up demand
from deferred projects which should keep our systems
areas fully employed well into the new millenium.
Third,
I believe all financial service firms need to be especially
vigilant about security, both in how their systems are
modified for Y2K compliance, and how they are implemented.
In particular, it may be tempting to relax electronic
security safeguards if problems occur. I would strongly
advise against this and Reserve Banks will be vigilant
here. The challenge of the new millenium will not be
lost on computer hackers, and the financial industry
must be particularly focused on this.
Finally,
let me reiterate the necessity for continued focused
attention on Y2K. Despite my reassuring assessment,
much remains to be done, and there are no guarantees
of total success. Everyone must concentrate on his or
her own piece of this effort. In that regard, to return
to my splash and ripple analogy, if all the efforts
of every firm and every country are firmly directed
and well-controlled, then the entire pond will be covered,
not with faint ripples, but with the splashes of success.
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