Norwest Corporation and Subsidiaries - Page 65

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          business deals of its customers that were not completed because it          
          was unable to transfer funds.                                               
               In response to the Federal Reserve's enforcement of the 5 p.m.         
          rule, NTS examined the timeliness of the MoneyNet system in terms           
          of logging and processing the wire transfers.  To protect itself in         
          the event the system crashed, NTS developed a contingency site22            
          (also known as a disaster site or hot site) in which all logs of            
          wire transfers were copied or mirrored from the production site to          
          a second site in real time.  Thus, if the production system failed,         
          the users could simply move over to the contingency site and                
          complete the transfers on that system.  At the same time, NTS               
          needed to quickly recover the production system from the point at           
          which it crashed so that the users could continue logging transfers         
          for its customers.                                                          
               The second major Federal Reserve regulatory change affecting           
          Norwest was the so-called daylight overdraft rule.  Often, because          
          of the large number of transfers to and from wire institutions,             
          many of which were not settled until the end of each business day,          
          some institutions maintained negative balances in their Federal             
          Reserve accounts during some part of the day, which placed a risk           


               22   The wire transfer system's lack of a contingency site             
          resulted in Norwest's being cited by the Office of the                      
          Comptroller of the Currency and Norwest's internal auditors                 
          because of the potential for large losses.                                  





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