Ed's latest essay entitled The Y2K Public Relations Battle: Convincing the Public You're Y2K OK raises a few questions. First, Ed mentions the lack of Y2K statements by several car manufacturers (Ford, Chrysler, Toyota, Honda, Volkswagen) as causing concern in light of the fact that both GM and BMW stated that their products WERE Y2K compliant. I am not sure why there should be concern since the prevailing attitude of Ed's essays as well as most of the posters to this board is "always extrapolate". So, when 'world renowned micoprocessor expert Bruce Beach' mentions possible embedded system problems at an anonymous oil refinery, we are told that this can be extrapolated to all embedded systems, all oil refineries, and even all industries in general since 'an emebedded chip is an embedded chip'. Any report of bugs, be it a grocery store, a bank, a refinery, etc. is immediately followed by the familiar extrapolation that this same bug 'obviously' must exist in all grocery stores, banks, refineries, etc.

So, in this case, why can we not extrapolate the experiences of GM and BMW to other car manufacturers? Since commonality of parts across manufacturers is very prevalent in the auto industry, why should we not assume that most other automobiles are also Y2K compliant?

Later in Ed's article, there is a statement about the FDIC which appears to be playing fast and loose with the facts. Ed even gives the link to the source which shows his conclusion to be wrong!

Ed says: Similarly, FDIC regulations specifically prohibit U.S. banks from disclosing the results of the Y2K "inspections" currently being carried out (see fdic.gov/banknews/fils/1998/fil9874.html).

The FDIC statement says: Information from Year 2000 assessments are governed by the same rules of confidentiality that apply to FDIC examinations for safety and soundness, compliance, information systems, and trust activities. Under Part 309 of the FDICs rules and regulations, disclosure of reports of examination, or any information contained in them, is strictly prohibited.

So, FDIC rules do not "specifically prohibit" banks from disclosing Y2K assessment results as the FDIC rules do not specifically mention Y2K. Member banks are prohibited from disclosing any information from examinations by the FDIC, Y2K related or not. This memo simply calrifies that there is no exception to standard FDIC rules for Y2K assessments. To say that they were specifically prohibited from disclosing the Y2K assessments implies something underheanded and unethical as opposed to the actual facts.

Further on in the FDIC memo it states: While the disclosure of Year 2000 assessment information is prohibited, the FDIC strongly encourages financial institutions to publicly disclose the steps they have taken to address Year 2000 issues, including their own evaluation of their compliance with Year 2000 guidance issued by the Federal Financial Institutions Examination Council (FFIEC). Such disclosures are an effective method for institutions to inform customers of their Year 2000 readiness, and are recommended by the FDIC. In FIL-52-98, Year 2000 Customer Awareness Guidance issued on May 13, 1998, the FDIC emphasized the importance of effective communication between institutions and their customers. In FIL-24-98, Discussion of Year 2000 Issues in Annual Disclosures issued on February 27, 1998, the FDIC highlighted the Securities and Exchange Commissions (SEC) Year 2000 disclosure requirements for publicly traded institutions. The FDIC also encouraged other institutions not subject to SEC requirements to use the SEC guidance as the basis for voluntary public disclosure about Year 2000 readiness.

So the FDIC is not stonewalling as Ed asserts. They simply said that member banks could not release the information from the FDIC's own Y2K assessment. Banks are free to -- and strongly encouraged to -- do their own assessments (like any other business) and communicate those results to the public.

In an article where Ed talks about PR organizations finding the right "positive spin", he seems to have found the correct "negative spin" to further his own agenda.

RMS

-- RMS (rms_200@hotmail.com), April 19, 1999

Answers

RMS - you've misunderstood what the FDIC memo actually means:

release of actual data is PROHIBITED by the FDIC (note that word prohibited - that means that they it CANNOT be released). In other words the FDIC is encouraging local banks to say nice things about their y2k compliance steps, but they must not ever actually tell anyone whether or not the FDIC - which is the organization which decides whether or not to allow them to continue operating - is in fact satisfied and will allow them to stay in business after 01/01/00.

So in point of fact the FDIC *is* stonewalling.

now what did you say your agenda was?

Arlin Adams

-- Arlin H. Adams (ahadams@ix.netcom.com), April 19, 1999.

And now, let the GI attacks begin.....They know all. How dare you question computer expert/engineer/economist/utility expert/automotive expert/banking authority/small-business analyst/market-watcher/ actor/singer/dancer/poet/spinner Ed Yourdon.

-- yyyyyyyy (heretheycome@pffft.com), April 19, 1999.

oh, and thanks for the pointer to Ed's latest - hadn't seen it yet, and so I've forwarded it to my entire y2k prep list as well.

Arlin

-- Arlin H. Adams (ahadams@ix.netcom.com), April 19, 1999.

The Federal Reserve and the SEC also have regulations regarding full disclosure. They have also instituted cut off dates for Y2K compliance that Wall Street and most money center banks have publicly said they will meet (which is, if memory serves, late this summer.) If that's the case, why have so many brokerage houses begun to turn up the Y2K heat this late in the ball game? Why is it that many of the biggest have now ammended their personnel policies to state that it is each individual empolyee's responsibility to ensure that their machine is Y2K compliant? Why is it that in at least one brokerage firm (which I can't name for fiduciary reasons) is actively dismembering programming teams and sucking all developers into the Y2K void in the Q1 '99? Why is it that I see hordes of Unix SAs running around 17 hours a day installing Y2K patches on all the serves and workstations? Why do I see hordes of Windows NT admins and support people running around doing Y2K compliance audits and patches 17 hours a day? Why is it that these issues aren't discussed in any PR work released by these firms, and that this information isn't in their annual reports?

On the subject of embedded systems, the main problem is that many of these systems, irrespective of their actual installation, share BIOS (Basic Input Output System) that is built on 2 digit date math. These systems need immediate upgrades to Y2K compliant versions. This isn't happening. To wit, has anyone contacted you to upgrade the BIOS in your alarm clock? How about your television? PC? Home heating/cooling system? Antilock braking system? Relevant controllers throughout your car?

Lastly, a small story of relevance. When I first started in the IT industry, I was doing some maintenance work on some production code that contained 2 digit date math. I asked why this code was here, and whether I should upgrade the algorithms to deal with 4 digit dates to circumvent any problems (this was 1987). My boss replied that there was no time or money to do that, and besides, "we won't be here in 13 years when that happens anyway".

I may not be at that firm any more, but I'm still in the industry and, frankly, I'm shocked by what I hear from the grapevine. I'm not directly involved in these efforts (I'm doing other development), but I do hear stories and, frankly, I'm sorried.

-- Eric Gufford (eric_gufford@acm.org), April 19, 1999.

RMS-
What DID you indicate your native reading language was???
The excerpt you printed says, in so many words, that release of 2000 evaluation information is prohibited. It does "specifically" prohibit the release of the evaluation, first, as anything else covered by part 309, and then on it's own merits. Please re-read your own quotes.

Information from Year 2000 assessments are governed by the same rules of confidentiality that apply to FDIC examinations for safety

And here:

While the disclosure of Year 2000 assessment information is prohibited,...

Perhaps you need a translator. Or more likely a sentence parser who will parse for you. CR

-- chuck, a Night Driver (rienzoo@en.com), April 19, 1999.

Oh yyyyyyyy, you exaggerate so much. Everyone knows Ed is a lousy singer.

-- rick blaine (y2kazoo@hotmail.com), April 19, 1999.

Ed Yourdon Rules.....

-- Apple (villarta@itsnet.com), April 19, 1999.

RMS,

I think you misunderstood the point of Ed's comment about the auto industry. Yes, you and I can extrapolate the experiences of GM and BMW to other automobile manufacturers, but will the general public do that? Ed wasn't saying that non-GM and non-BMW cars might not be compliant; his concern was that the public might be reluctant to buy a new car if it cannot find any information, good or bad, about the Y2K compliance of the model it was interested in.

As for the FDIC, I think the public would be more willing to believe what the FDIC has to say about their local bank rather than what that bank claims about their own Y2K compliance. Ed Yourdon used the word "stonewalling" with quotation marks. The FDIC doesn't normally release this type of information, but it might be necessary to release it to calm the public.

If the government isn't willing to assure the general public about particular banks, then you can't blame the public if they choose to be concerned about this issue. What would it hurt anyway? Banks were supposed to have substantially completed testing by December 31, 1998.

-- Kevin (mixesmusic@worldnet.att.net), April 19, 1999.

Eric, that's the first time I've read that workers are scurrying around patching. That is welcome good news! At the end of your post did you mean "worried?" Sorried would fit too  ;-)

-- Leska (allaha@earthlink.net), April 19, 1999.

... "For example, the International Air Transport Association (IATA) recently announced that its $20 million project to compile a list of non-compliant airports will not be released to the public until after Jan 1, 2000 -- because to do so would be "scaremongering." ... -- Ed Yourdon's essay

Uh, RMS ... how is that NOT "spin?"

Eventually, some smart Y2K corporations, who ARE really compliant, WILL advertise the news.

Can you spell "competitive advantage?"

Diane

-- Diane J. Squire (sacredspaces@yahoo.com), April 19, 1999.

Hey RMS: Have you had any luck locating the clock chip in your VCR or have you realized that you are not really an embedded systems expert?

-- a (a@a.a), April 19, 1999.

Hey a: Have you had any luck locating your head in your ass or have you realized that you embedded it much to expertly?

-- (bozoalert@whata.jerk), April 19, 1999.

A couple of quick points.

The FDIC prohibits banks from releasing the results of FDIC audits. Banks are permitted, and encouraged, to release results of any other audits, like their own, or IV&V audits, etc.

Also, I find it curious that Yourdon is arguing that IF people start to become visibly worried about y2k, releasing the actual truth will calm them down. OK, people might worry worse if you start spending PR money insisting you're all right when that's what most people thought all along. More and more, I'm starting to believe that releasing the unvarnished facts would indeed calm down all but the most committed doomboobs on this forum.

-- Flint (flintc@mindspring.com), April 19, 1999.

Flint -- You're just STARTING to believe this? There really are times when I am amazed by your comments. Releasing the unvarnished facts was ALWAYS the best (not only the most ethical, though it is, but the most practical) course, as Yardeni has been doggedly trying to persuade people of for two years. Infantilizing the citizenry is always dumb and especially when a real crisis might be brewing (cf Vietnam for a good political example and, perhaps, Kosovo as well as Y2K).

-- BigDog (BigDog@duffer.com), April 19, 1999.

...unless of course, the "unvarnished facts" are scarier than even Flint had imagined...

-- a (a@a.a), April 19, 1999.