ARLINGTON, Va. -- NCUA plans to issue guidance similar to the one from the Office of the Comptroller of the Currency on the approaching change in Daylight Savings Time that could pose risks to banks that are not prepared.
The Energy Policy Act of 2005 changes the date for DST from the first Sunday in April to the second Sunday in March. The OCC's guidance said that without preparation, "banks could experience logging errors, monitoring difficulties, degraded system performance, or disruptions of some services. In addition, malfunctioning systems could result in compliance errors (e.g., incorrect ATM disclosures) and securities issues (e.g., malfunctioning security systems).
"Bank management should understand the potential impact of the DST change on its hardware and software and plan for appropriate changes." OCC reminded that other systems like heating and air conditioning, lighting, alarms, telephone systems and others could be affected.
NCUA plans to issue a letter to credit unions on the subject shortly.
NAFCU President/CEO Fred Becker pointed to the seamless Y2K transition. "I wasn't here at the time, but I can remember watching Navy Federal in Guam, who was the first to switch the times, and there were no problems. I anticipate we'll get through it similarly given that this is a three minute change."
To ensure readiness, OCC recommended that management:
oReview and verify modifications necessary for all important systems and essential processes, including servers, applications, and utility systems.
oEnsure that critical systems will synchronize and function properly by testing or other means.
oDetermine which systems are connected to the USNO Master (Atomic) Clock through a network time protocol (NTP or NTPD) and whether they will synchronize with the master clock at the appropriate moment.
oContact third-party service providers to ensure the institution is protected.
oDetermine whether systems require a manual procedure to be performed and whether a follow-up plan is needed.
oEnsure that system's adjustments will not be duplicated when the historic change date occurs.
oEnsure that all employees are alerted to the change.