Norwest Corporation and Subsidiaries - Page 63

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          time from its accounts, through the Federal Reserve System (the             
          Federal Reserve), to the destination financial institutions.19  (The        
          software also permitted transfers from other institutions to                
          Norwest.)  During the years in issue, NTS was engaged in many               
          projects20 designed to address Federal Reserve regulatory changes           
          and Norwest's business needs. (Norwest was experiencing a large             
          growth in the wire transfer business--20 percent or more per                
          year.21)                                                                    



               19   To effectuate a wire transfer of funds, Norwest set up            
          a contra account (also known as a due-to/due-from account) with             
          the Federal Reserve.  When a Norwest customer wanted to make a              
          transfer, Norwest would debit the customer's account and credit             
          its own account at the Federal Reserve.  The Federal Reserve                
          would then debit Norwest's account and credit the destination               
          institution's account.  This procedure was used for all domestic            
          wire transfers; international wire transfers did not go through             
          the Federal Reserve.                                                        
               Initially, the wire transfer system used by Norwest did not            
          provide for international wire transferring of funds.                       
          International transfers occurred through other, antiquated,                 
          systems which were manual and paper based.  Norwest converted the           
          international wire transferring to the MoneyNet system, which               
          provided on-line, real-time transfers and validation.  This was a           
          large project that took several months of work.                             
               20   Some of the smaller projects included additions and               
          changes to the screen and reporting functions of the system.                
               21   Norwest was processing approximately $5 to $7 billion             
          in wire transfers per day.  The expansion of this business raised           
          critical security issues that had to be addressed any time new              
          technology was instituted.  (In fact, Norwest was the victim, on            
          at least one occasion, of a fraudulent wire transfer ring that              
          infiltrated the system.)  Thus, any software development was                
          constrained by security concerns.                                           





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