AL 98-14
Subject: Fiduciary Services and Year 2000 Readiness
Date: September 3, 1998

TO:    Chief Executive Officers of National Banks, Department
       and Division Heads, and Examining Personnel


This advisory is to alert you to the recent release of an FFIEC
interagency statement on the Year 2000 problem.  "Guidance
Concerning Fiduciary Services and Year 2000 Readiness," a
supplement to previous FFIEC interagency statements, guides
banks in overseeing and managing the risks posed by the Year
2000 problem to fiduciary services.  The guidance describes
the responsibilities of senior management and the board of 
directors in this area, and outlines the controls and actions 
banks should use to manage the risks to their fiduciary 
activities.  Such controls and actions will be determined by 
the types of fiduciary services a bank offers and the nature 
of the assets it manages.  The guidance also describes such
specific areas of potential concern as account and asset 
administration, third-party risk, counterparty risk, transfer 
agent services, and client disclosures. Financial institutions 
should work to prevent Year 2000 problems that could affect their 
fiduciary clients.  Beneficiaries and other interested parties 
may interpret a financial institution's lack of response as a 
failure to fulfill its fiduciary duties.  For further information 
on fiduciary services and Year 2000 readiness please contact the 
Asset Management Division at (202) 874-4447.


                                                                                 
Emory W. Rushton
Senior Deputy Comptroller
Bank Supervision Policy



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