The Federal Deposit Insurance Corp. has less than 100 business days to examine how more than 4,000 banks are handling the year- 2000 problem.
That's at least 40 banks a day.
What's worse, FDIC examiners must return to the more than 2,000 banks already evaluated because the General Accounting Office found the agency's first reviews inadequate.
Michael J. Zamorski, deputy director of the FDIC's supervision division and head of its year-2000 task force, says the agency's specially trained examiners will meet their June 30 deadline.
"Even though we have 6,200 institutions, they tend to be smaller and much simpler organizations than the larger, complex organizations" that the Office of the Comptroller of the Currency and the Federal Reserve Board oversee, said Mr. Zamorski.
But FDIC's examiners will have to pick up the pace. The agency is just one-third of the way through its exams.
By comparison, the Comptroller's Office and the Federal Reserve have completed about half their year-2000 exams.
As of Dec. 31, the Comptroller's Office had visited 1,255 of the 2,600 national banks it supervises, while Fed examiners had evaluated 920 of its 1,849 state banks.
Additional questions recommended by the GAO will only add to the year- 2000 burdens on FDIC examiners.
The current on-site evaluation procedures-used by all bank regulators, not just the FDIC-require examiners to ask 15 to 41 questions about each bank. Some are broad queries that require significant research time, and place a premium on the examiner's judgment.
For example, just one question asks the examiner to determine if the bank has:
identified risks associated with licensing and maintenance agreement protections in third-party software contracts;
determined whether data processing outsourcing agreements have year- 2000 maintenance obligations;
considered leap years in its contract reviews;
established a process to certify that vendors and products are year- 2000 compliant.
To these questions, GAO wants to add its own. Without them, the agency said, examiners may err in their estimation of a bank's year-2000 readiness. Though GAO provided no concrete examples of examiner error, the FDIC said it would comply with the request.
GAO is not alone in fretting over the year-2000 exams. "Many examiners don't completely understand the issue and need more training," said a bank consultant.
But the FDIC's Zamorski countered that his examiners are well-seasoned, with an average tenure of 12 years.
So far, banking industry trade groups have shown patience with the on- site examinations.
"I think most bankers understand the seriousness of the problem and that it's appropriate for the agencies" to be tracking banks' efforts, said Karen M. Thomas, director of regulatory affairs at the Independent Bankers Association of America. But, she added, it is "too early" to tell how banks will react to the new round of questions.
Last week, all five bank regulators submitted year-2000 progress reports to the House and Senate Banking Committees.
GAO, at the behest of Congress, is evaluating the year-2000 progress of every banking agency. Reports on the National Credit Union Administration and the FDIC have been issued, while an analysis of the Office of Thrift Supervision's efforts is expected in the next month or two. Reports on the Federal Reserve and the Comptroller's Office will follow.
GAO is likely to recommend that all of these agencies, not just the FDIC, go back to the institutions they supervise and ask additional questions.