AL 2000-1
Subject: Leap Year Day and Remaining Year 2000 Risks
Date: February 14, 2000	

To: Chief Executive Officers of All National Banks, 
    Federal Branches, Service Providers, Software Vendors, 
    and All Examining Personnel 

This advisory reminds management of banks, service 
providers, and software vendors of potential Year 
2000-related risks subsequent to the century date change.  

Some critical dates still have the potential to cause 
information systems to malfunction.  Therefore, 
management should continue to identify and control 
the risks posed by both internally identified critical 
dates, as well as the remaining critical dates identified 
in the April 10, 1998, FFIEC Interagency Statement, 
Guidance Concerning Testing for Year 2000 Readiness.
 
In addition, management should remain vigilant for 
other Year 2000-related risks that may occur.  Such 
risks include undetected data corruption in bank programs 
and files, financial strains on bank customers who 
encounter Year 2000-related problems, and temporary 
Year 2000 fixes that may need further remediation at 
a later date.  Management, in consultation with legal 
counsel, also should ensure that the institution retains 
appropriate documentation associated with its Year 2000 
efforts to demonstrate that it has fulfilled its fiduciary, 
contractual, and regulatory responsibilities in the event 
of third-party litigation. 

The next FFIEC-identified critical date is February 29, 2000.  
Given the minimal problems encountered over the century date 
change period, the OCC will not contact every institution 
on this date.  However, management of national banks and 
OCC-supervised service providers and software vendors are 
expected to promptly report to their examiners any substantive 
Year 2000-related problems related to this critical date or 
any other Year 2000-related risk.  A substantive Year 
2000-related problem is one that is not easily correctable 
or that poses a broader risk to the industry. 




Emory W. Rushton
Senior Deputy Comptroller, Bank Supervision Policy