Federal Reserve Banks: Areas for Improvement in Computer Controls (Letter
Report, 10/14/98, GAO/AIMD-99-6).

Pursuant to a legislative requirement, GAO reviewed the general and
application computer controls over key Financial Management Service
(FMS) and Bureau of the Public Debt (BPD) financial systems maintained
and operated by the 12 Federal Reserve Banks (FRB).

GAO noted that: (1) overall, GAO found that FRBs had implemented
effective computer controls; (2) however, GAO identified vulnerabilities
in computer controls involving: (a) access to systems, programs, and
data, including unauthorized external access; (b) service continuity and
contingency planning; and (c) access controls over certain financial
applications; (3) while these vulnerabilities do not pose significant
risks to the BPD and FMS financial systems, they warrant FRB
management's attention and action to decrease the risk of inappropriate
disclosure or modification of sensitive information or disruption of
critical operations; (4) FRBs have corrected or are correcting the
vulnerabilities that GAO identified; (5) GAO provided a general summary
of the vulnerabilities that existed on September 30, 1997; (6) those
that GAO verified had been fully resolved subsequent to September 30,
1997, GAO has so noted; and (6) GAO will review the status of FRBs'
corrective actions during GAO's audit of the federal government's fiscal
year 1998 consolidated financial statements.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-99-6
     TITLE:  Federal Reserve Banks: Areas for Improvement in Computer 
             Controls
      DATE:  10/14/98
   SUBJECT:  Confidential communication
             Computer security
             Federal agency accounting systems
             Financial management systems
             Data integrity
             Financial statement audits
             Internal controls

             
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Cover
================================================================ COVER


Report to the Chairman of the Board of Governors of the Federal
Reserve System

October 1998

FEDERAL RESERVE BANKS - AREAS FOR
IMPROVEMENT IN COMPUTER CONTROLS

GAO/AIMD-99-6

Computer Controls at FRBs

(919304)


Abbreviations
=============================================================== ABBREV

  BPD - Bureau of the Public Debt
  FMS - Financial Management Service
  FRB - Federal Reserve Bank
  ID - identification

Letter
=============================================================== LETTER


B-280753

October 14, 1998

The Honorable Alan Greenspan
Chairman
Board of Governors of the Federal Reserve System

Dear Mr.  Chairman: 

We recently reported on the U.S.  government's consolidated financial
statements for fiscal year 1997 (GAO/AIMD-98-127, March 31, 1998). 
Our audit was done pursuant to the Chief Financial Officers Act of
1990, as expanded by the Government Management Reform Act of 1994. 
Our review of the general and application computer controls over key
Financial Management Service (FMS) and Bureau of the Public Debt
(BPD) financial systems maintained and operated by the 12 Federal
Reserve Banks (FRB) was performed as part of this audit.  Today, we
issued a "Limited Official Use" report detailing vulnerabilities in
both general and application computer controls.  This version of the
excerpted report for public release provides a general summary of the
vulnerabilities we identified and the recommendation we made. 

This report discusses general and application controls over the key
FMS and BPD financial systems that are maintained and operated by
FRBs.  FRBs, as fiscal agents and depositories of the federal
government, provide services that primarily consist of handling
collections, disbursements, and issuance and redemption of debt. 

General controls affect the overall effectiveness and security of
computer operations as opposed to being unique to any specific
computer application.  They are intended to (1) protect data, files,
and programs from unauthorized access, modification, and destruction,
(2) prevent the introduction of unauthorized changes to systems and
applications software, (3) ensure that system software development
and maintenance, applications software development and maintenance,
computer operations, security, and quality assurance functions are
performed by different people, (4) ensure recovery of computer
processing operations in case of a disaster or other unexpected
interruption, and (5) ensure that an adequate computer security
planning and management program is in place. 

Application controls are the structure, policies, and procedures that
apply to individual application systems.  These controls help to
ensure that transactions are valid, properly authorized, and
completely and accurately processed by the computer. 

We found that FRBs had implemented effective computer controls over
key BPD and FMS financial systems that they maintained and operated. 
However, as discussed in this report, we identified vulnerabilities
involving computer controls that if left uncorrected, could increase
the risk of inappropriate disclosure or modification of sensitive
information or disruption of critical operations.  These
vulnerabilities warrant FRB management's attention and action. 

During the process of performing our work, we provided detailed
information on our interim findings and recommended corrective
actions to FRB management.  This report summarizes those findings. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Overall, we found that FRBs had implemented effective computer
controls.  However, we identified vulnerabilities in computer
controls involving (1) access to systems, programs, and data,
including unauthorized external access, (2) service continuity and
contingency planning, and (3) access controls over certain financial
applications.  While these vulnerabilities do not pose significant
risks to the BPD and FMS financial systems, they warrant FRB
management's attention and action to decrease the risk of
inappropriate disclosure or modification of sensitive information or
disruption of critical operations. 

FRBs have corrected or are correcting the vulnerabilities that we
identified.  The following discussion provides a general summary of
the vulnerabilities that existed on September 30, 1997.  Those that
we verified had been fully resolved subsequent to September 30, 1997,
we have so noted.  We will review the status of FRBs' corrective
actions during our audit of the federal government's fiscal year 1998
consolidated financial statements. 


   BACKGROUND
------------------------------------------------------------ Letter :2

FRBs perform fiscal agent and depository services on behalf of the
U.S.  government, including FMS and BPD.  These services primarily
consist of handling collections, such as accepting deposits of
federal taxes, fees, and other receipts; providing payment-related
services, such as maintaining Treasury's checking account and
handling the government's disbursements, including clearing checks
and making electronic payments; and providing debt-related services,
such as issuing, servicing, and redeeming Treasury securities,
processing secondary market transactions, and handling the related
transfers of funds.  In fiscal year 1997, Treasury collected over
$1.5 trillion in taxes, duties, and fines; disbursed approximately $1
trillion for Social Security and Veterans benefits, tax refunds,
federal employee salaries, and vendor billings; and issued more than
$2 trillion in public debt. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :3

Our objectives were to evaluate and test the effectiveness of the
general computer and application controls over key financial
management systems maintained and operated by FRBs on behalf of FMS
and BPD. 

Specifically, we evaluated general controls intended to

  -- protect data, files, and programs from unauthorized access,
     modification, and destruction;

  -- prevent the introduction of unauthorized changes to systems and
     applications software;

  -- provide adequate segregation of duties involving applications
     and system programmers and of responsibilities for computer
     operations, security, and quality assurance;

  -- ensure the recovery of computer processing operations in case of
     a disaster or other unexpected interruption; and

  -- ensure that an adequate computer security planning and
     management program is in place. 

To evaluate general controls, we identified and reviewed FRBs'
information system general control policies and procedures, conducted
tests and observations of controls in operation, and held discussions
with officials at the locations visited to determine whether the FRB
general controls were in place, adequately designed, and operating
effectively.  Further, we attempted to obtain access to sensitive
data and programs.  These attempts, referred to as penetration
testing, were performed with the knowledge and cooperation of FRB
officials. 

We also evaluated application controls intended to ensure that

  -- access privileges establish individual accountability and proper
     segregation of duties, limit the processing privileges of
     individuals, and prevent and detect inappropriate or
     unauthorized activities;

  -- data are authorized, converted to an automated form, and entered
     into the application accurately, completely, and timely;

  -- data are properly processed by the computer and files are
     updated correctly; and

  -- files and reports generated by the application represent
     transactions that actually occur and accurately reflect the
     results of processing, and reports are controlled and
     distributed to the authorized users. 

To assist in our evaluation and testing of computer controls, we
contracted with the independent public accounting firm Price
Waterhouse, LLP (now PricewaterhouseCoopers).  We determined the
scope of our contractor's audit work, monitored its progress, and
reviewed the related work papers to ensure that the resulting
findings were adequately supported. 

During the course of our work, we communicated interim findings and
recommended corrective actions to FRB management who informed us that
FRBs have taken or plan to take corrective action to address the
vulnerabilities we identified.  We plan to follow up on these matters
during our audit of the federal government's fiscal year 1998
consolidated financial statements. 

We performed our work at FRB data centers in Atlanta, Georgia;
Minneapolis, Minnesota; New York, New York; Pittsburgh, Pennsylvania;
Richmond, Virginia; East Rutherford, New Jersey; San Francisco,
California; and Dallas, Texas, from March 1997 through January 1998
in accordance with generally accepted government auditing standards. 
We requested comments on a draft of this report from the Chairman of
the Board of Governors of the Federal Reserve System or his designee. 
The board's comments are reprinted in appendix I. 


   AREAS FOR IMPROVEMENT IN
   GENERAL COMPUTER CONTROLS
------------------------------------------------------------ Letter :4

Our review of the FRB general computer controls did not identify any
weaknesses that placed the financial systems operated and maintained
for FMS and BPD at significant risk of being accessed, compromised,
or destroyed.  However, we identified vulnerabilities in access
controls and service continuity and contingency planning that warrant
management's attention and action.  These vulnerabilities, if left
uncorrected, increase the risk that inappropriate disclosure or
modification of sensitive information or disruption of critical
operations could occur and not be detected or prevented in a timely
manner. 


      ACCESS CONTROLS
---------------------------------------------------------- Letter :4.1

Access controls are designed to limit or detect access to computer
programs, data, equipment, and facilities in order to protect these
resources from unauthorized modification, loss, or disclosure.  Such
controls include logical and systems software controls and physical
controls. 

Logical controls include user identifications (ID), passwords, or
other identifiers and security software programs.  Logical controls
restrict the access of legitimate users to the specific systems,
programs, and files they need to conduct their work and to prevent
unauthorized users from gaining access to computing resources. 
Controls over access to and modification of system software are
essential to protect the overall integrity and reliability of
information systems. 

Physical security controls include locks, guards, badges, alarms, and
similar measures (used alone or in combination) that help to
safeguard computer facilities and resources from espionage, sabotage,
damage, and theft. 

Our review of FRB access controls identified vulnerabilities that
related to (1) granting systems privileges to users, (2) management
of passwords and user IDs, (3) setting security software options in a
manner to ensure optimum security or appropriate segregation of
duties, (4) management of physical access to certain system
resources, and (5) management of local area network and Internet
dial-in activities. 

We verified that corrective actions to resolve two of the individual
vulnerabilities had been completed by FRBs subsequent to September
30, 1997. 


      SERVICE CONTINUITY AND
      CONTINGENCY PLANNING
---------------------------------------------------------- Letter :4.2

An organization's ability to accomplish its mission can be
significantly impacted if it loses the ability to process, retrieve,
and protect information that is maintained electronically.  For this
reason, organizations should have (1) established procedures for
protecting information resources and minimizing the risk of unplanned
interruptions and (2) contingency plans for recovering critical
operations should interruptions occur. 

A contingency plan specifies emergency response, backup operations,
and postdisaster recovery procedures to ensure the availability of
critical resources and facilitate the continuity of operations in an
emergency situation.  It addresses how an organization will deal with
a full range of contingencies, from electrical power failures to
catastrophic events, such as earthquakes, floods, and fires.  The
plan also identifies essential business functions and prioritizes
resources in order of criticality.  To be most effective, a
contingency plan should be periodically tested and employees should
be trained in and familiar with its use. 

In reviewing FRBs' service continuity and contingency planning, we
found that adequate tests of certain aspects of the disaster recovery
plans were not being conducted at two sites and plans and related
backup equipment for one financial system were not updated to
accommodate system changes. 


   APPLICATION CONTROLS CAN BE
   STRENGTHENED
------------------------------------------------------------ Letter :5

Our review of the FRB application controls over financial systems
operated and maintained for FMS and BPD identified opportunities for
improvements in authorization controls. 


      AUTHORIZATION CONTROLS
---------------------------------------------------------- Letter :5.1

Authorization controls are designed to ensure that only approved
transactions are entered into the application systems and processed
by the computer.  We found problems related to (1) limiting users to
those system processing functions and transactions required for the
users' job responsibilities and (2) inadequate or incomplete
documentation for granting users access to applications. 


   CONCLUSION
------------------------------------------------------------ Letter :6

Overall, we found that FRBs had implemented effective computer
controls over key BPD and FMS financial systems that they maintained
and operated.  However, we identified vulnerabilities that, while
they do not pose significant risks to the BPD and FMS financial
systems, warrant FRB management's attention and action to decrease
the risk of inappropriate disclosure or modification of sensitive
information or disruption of critical operations. 


   RECOMMENDATION
------------------------------------------------------------ Letter :7

To improve areas of vulnerability in general controls and application
controls cited in our "Limited Official Use" version of this report,
we recommended that you (1) assign cognizant FRB officials
responsibility and accountability for correcting each individual
vulnerability that we identified and communicated to FRB management
during our testing and (2) direct the Director of the Division of
Reserve Bank Operations and Payment Systems to monitor the status of
all vulnerabilities, including actions taken to correct them. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

In commenting on a draft of this report, the Board of Governors of
the Federal Reserve System agreed with our assessment that FRBs have
implemented effective computer controls and that while the
vulnerabilities identified do not pose significant risks to the
Treasury's financial systems, they warrant FRB management's
attention.  The board stated that they have implemented our
recommendation and that FRBs are in the process of correcting the
vulnerabilities identified in our report to the extent possible.  We
will follow up on these matters during our audit of the federal
government's fiscal year 1998 consolidated financial statements.  In
addition to its written comments, the staff of the Board of Governors
of the Federal Reserve System provided technical comments, which have
been incorporated as appropriate. 


---------------------------------------------------------- Letter :8.1

We are sending copies of this report to the Director of the Office of
Management and Budget, and to the Chairmen and Ranking Minority
Members of the Senate Committee on Appropriations and its
Subcommittee on Treasury and General Government; Senate Committee on
Finance; Senate Committee on Governmental Affairs; Senate Committee
on the Budget; House Committee on Appropriations and its Subcommittee
on Treasury, Postal Service, and General Government; House Committee
on Ways and Means; House Committee on Government Reform and Oversight
and its Subcommittee on Government Management, Information and
Technology; and House Committee on the Budget.  We will also send
copies to others upon request. 

This work was performed under the direction of Gary T.  Engel,
Associate Director, Governmentwide Audit and Financial Management
Issues, who can be reached at (202) 512-3406.  Other major
contributors to this report are listed in appendix II. 

Sincerely yours,

Gene L.  Dodaro
Assistant Comptroller General




(See figure in printed edition.)Appendix I
COMMENTS FROM THE FEDERAL RESERVE
SYSTEM
============================================================== Letter 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C. 

Christine A.  Robertson, Assistant Director
Paula M.  Rascona, Audit Manager
Gregory C.  Wilshusen, Assistant Director - Technical Advisor


*** End of document. ***