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XI

UNITED STATES OF AMERICA
BEFORE THE BOARD OF GOVERNORS

OF THE FEDERAL RESERVE SYSTEM

WASHINGTON,

In the Matter of

Docket No. 9%034-B-SM
Cease and Desist Order
Issued Upon Consent
Pursuant to the Federal
Deposit Insurance Act,
as Amended

Zia New Mexico Bank

Tucumcari, New Mexico

WHEREAS,
and information

D.C.

in recognition

of their common goal to maintain the integrity of the records

systems of the Zia New Mexico Bank, Tucumcari,

New Mexico (the “Bank”), a

state chartered bank that is a member of the Federal Reserve System, and to ensure that all
mission-critical

systems of the Bank will continue to be fully functional before, on, and after

January 1,2000, the Board of Governors of the Federal Reserve System (the “Board of
Governors”) and the Bank have mutually agreed to enter into this consent Cease and Desist
Order (the “Order”); and

WHEREAS,on

DECEMBER 7

,

1998, the board of directors of the Bank, at a duly

constituted meeting, adopted a resolution (1) authorizing
enter into this Order on behalf of the Bank, and consenting

and directing

3 0 H N P HAL E N

to compliance

provision of this Order by the Bank and its institution-affiliated

to

with each and every

parties, as such term is defined in

section 3(u) of the Federal Deposit Insurance Act, as amended (the “FDI Act”) (12 U.S.C.
18 13(u)); (2) waiving the issuance of a notice of charges and of hearing on any matter set forth in

this Order relating to the Bank; (3) waiving a hearing for the purpose of taking evidence on any
matter set forth in this Order; (4) waiving any all rights to contest the issuance of a cease and
desist order by the Board of Governors pursuant to 12 U.S.C. 18 18 and 12 C.F.R. Part 263; and
(5) waiving any and all rights to challenge or contest in any manner the basis, issuance, validity,
terms, effectiveness,

or enforceability

NOW, THEREFORE,

of this Order or any provisions hereof.

before the taking of any testimony or adjudication

any issue of fact or law herein, and without this Order constituting
allegation made or implied by the Board of Governors in connection

an admission of any
with this proceeding:

IT IS HEREBY ORDERED that the Bank and its institution’-affiliated
following affirmative

of or finding on

parties take the

actions:

1. The Bank shall take the following actions to ensure that its internal and external
mission-critical

systems are Year 2000 compliant:

(a) Within 10 days of this Order, appoint a senior manager, acceptable to the
Federal Reserve Bank of Dallas (the “Reserve Bank”) and accountable to the board of directors,
who will be responsible

for supervising the Bank’s Year 2000 readiness efforts and will devote a

substantial amount of time to Year 2000 compliance
staff is necessary to support this effort;

matters, and appoint whatever additional

(b) within 10 days of this Order, identify and allocate financial and other
resources necessary to achieve Year 2000 compliance;

(c) within 30 days of this Order, submit to the Reserve Bank an acceptable plan
for the renovation of all internal and external mission-critical

systems;

(d) within 30 days of this Order, submit to the Reserve Bank acceptable test plans
for all renovated or modified internal and external mission-critical

(e) Within 45 days of this Order, identify customers,

systems;

including funds takers and

funds providers, that represent material risk to the Bank, evaluate their Year 2000 preparedness,
assess their existing and potential Year 2000 risk to the Bank, and implement appropriate risk
controls, including controls for underwriting

risk, to manage and mitigate their Year 2000 risk to

the Bank; and

(I) within 45 days of this Order, submit to the Reserve Bank an acceptable
remediation contingency

plan that describes how the Bank will mitigate the risks associated with

the failure to complete successfully
external mission-critical

2.

its renovation, testing, and implementation

of its internal and

systems.

(a) Within 10 days of this Order, the Bank shall designate a senior manager,

acceptable to the Reserve Bank and accountable to the board of directors, who will be

3

responsible

for supervising

the Bank’s Year 2000 business resumption

contingency

planning

process.

(b) Within 30 days of this Order, the Bank shall submit to the Reserve Bank an
acceptable written program for the development

of a Year 2000 business resumption contingency

plan to mitigate operational risks that may be caused by failures of the Bank’s core business
processes.

The program shall, a minimum,

Bank’s business resumption

contingency

the plan as needs and circumstances

include and address the following four phases of the

planning process and provide for the periodic update of

require:

(1) The establishment

of organizational

planning guidelines that define

the Bank’s business continuity planning strategy;

(2) the development
impact of mission-critical

of a business impact analysis to assess the potential

system failures on the Bank’s core business processes;

(3) the identification
business resumption contingency

of circumstances

and trigger dates under which the

plan will be activated; and

(4) the establishment

of a method of validating the plan for effectiveness

and viability.

4

(c) The business impact analysis described in paragraph 2(b)(2) hereof must be
completed within 60 days of this Order.

3. The board of the directors of the Bank shall (a) meet at least once every two weeks to
review and monitor the Bank’s Year 2000 compliance

efforts, and (b) maintain full and complete

minutes of its actions relating to the Bank’s Year 2000 compliance

efforts, which shall be

submitted to the Reserve Bank within 5 days of each board meeting.

4. Within 5 days of the end of each month following the date of this Order, the Bank
shall furnish to the Reserve Bank written progress reports detailing the form and manner of all
actions taken to secure compliance
discontinued

with this Order and the results thereof.

Such reports may be

when the Reserve Bank has, in writing, released the Bank from making further

reports.

5. The plans and program required by paragraphs
be submitted to the Reserve Bank for review and approval.

l(c), (d), and (f), and 2(b) hereof shall
The Reserve Bank may comment on

the plans. Acceptable plans shall be submitted to the Reserve Bank within the time periods set
forth in this Order. The Bank shall adopt all approved plans within 10 days of approval by the
Reserve Bank and then shall fully comply with them. During the term of this Order, the Bank
shall not amend or rescind the approved plans without the prior written approval of the Reserve
Bank.

5

6. All communications

regarding this Order shall be sent to:

(a)

Mr. Basil J. Asaro
Vice President
Federal Reserve Bank of Dallas
P.O. Box 655906
Dallas, Texas 75265-5906

00

Ms. Marguerite Poling
Chairman of the Board
Zia New Mexico Bank
P.O. Box 1248
Tucumcari, New Mexico

8840 1

7. The provisions of this Order shall be binding upon the Bank and each of its institutionaffiliated parties, in their capacities as such, and their successors and assigns.

8. Each provision of this Order shall remain effective and enforceable

until stayed,

modified, terminated or suspended by the Board of Governors.

9. Notwithstanding

any provision of this Order to the contrary, the Reserve Bank may, in

its sole discretion, grant written extensions of time to the Bank to comply with any provision of
this Order.

10. The provisions of this Order shall not bar, estop, or otherwise prevent any federal or
state agency or department
or former institution-affiliated

from taking any other action affecting the Bank or any of its current
parties and their successors or assigns.

6

11. This Order does not supersede the Order issued against the Bank and G.A. Poling, Jr.
by the Board of Governors on June 23,1997,

which remains in effect.

By order of the Board of Governors of the Federal Reserve System effective this
)4

*

dayou

1998.

ZIA NEW MEXICO BANK

The undersigned

BOARD OF GOVERNORS OF THE
FEDERAL RESERVE SYSTEM

directors of the Bank each acknowledge

approve of the consent thereto by the Bank.

having read the foregoing Order and