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Document 2676822
iv ed System Operator: Reserve Bank of New Zealand Custodian Trustee: New Zealand Central Securities Depository Limited (NZCSD) Ar ch Report on controls over the NZClear system For the year ended 30 June 2014 Reserve Bank of New Zealand Table of contents Purpose, scope and use of this report 3 Section II Report by management 4 Section III Description of the Reserve Bank’s NZClear system 7 Section IV NZClear control objectives 13 Section V Independent assurance report 15 Section VI Definition of testing terms 17 Section VII Auditor’s tests of operating effectiveness of key controls 18 Ar ch iv ed Section I 2 Section I Purpose, scope and use of this report This report is designed to provide information to be used for financial reporting purposes by members of NZClear (“the System”) and their independent auditors in respect of the year ended 30 June 2014. This report is prepared pursuant to Rule 19.2.1 of the NZClear Rules which requires that an audit report for 1 the System be prepared and published each year . The report has been prepared in compliance with the requirements of the International Standard on Assurance Engagements (New Zealand) 3402 “Assurance Reports on Controls at a Service Organisation” issued by the External Reporting Board. This report comprises: a report by management which describes the services provided by the Reserve Bank of New controls for NZClear; iv ed Zealand (the “Reserve Bank”) as operator of the System including information on key internal an assurance report by Chris Barber with the assistance of PricewaterhouseCoopers (“PwC”) – on behalf of the Auditor-General (“the Auditor”); and details of the controls supporting each control objective, as well as the related tests performed by ch the Auditor and the results of that testing. The scope of this report is limited to the controls which apply to the operation of the System by the Reserve Bank and its use by members pursuant to the NZClear Rules. This report is strictly confidential. It is intended for use by the Reserve Bank, members of the NZClear Ar system and their independent auditors. Unauthorised use of this report in whole or part is strictly prohibited. 1 The NZClear Rules require that the Auditor issue a report on NZClear controls annually in respect of the period ended 30 June. In addition, the NZClear Rules require that for each three months ended 31 March, 30 September and 31 December the auditor will test the reconciliation of securities recorded in the NZClear system and those recorded in the respective registry records and issue a report on its findings. 3 iv ed ch Ar iv ed ch Ar iv ed ch Ar Section III Description of the Reserve Bank’s NZClear system Background on NZClear NZClear is New Zealand’s principal high-value securities depository. The System is charged with providing an efficient and safe process for the electronic transfer and safekeeping of securities. NZClear, known formerly as the Austraclear New Zealand System, has been operating in New Zealand since 1990 and is used principally for transferring fixed interest securities and equity securities on a delivery versus iv ed payment basis. The System is also used to make transfers of cash between participants. For a transaction to be settled both parties must enter the relevant details of the transaction and those transaction details must be “matched” by the System. Once a transaction is matched, to be further processed a payor of funds must have sufficient funds or credit facilities with its clearing bank (known in the Rules as the Participating ESAS Account Holder) and the seller of securities must have sufficient securities in its security account to complete the transaction. Settlement is effected by a process called Delivery versus ch Payment (“DvP”) (Bank for International Settlements Model 1) whereby settlement of securities and associated cash payments occurs on an irrevocable and simultaneous basis. Cash payments involving more than one Participating ESAS Account Holder are made across the Reserve Bank’s Exchange Settlement Ar Account System, while title to securities is transferred in the NZClear system. Once a transaction is settled it cannot be revoked. NZClear is a designated settlement system under part 5C of the Reserve Bank Act 1989. NZClear is jointly regulated by the Financial Markets Authority and the Prudential Supervision Department of the Reserve Bank of New Zealand. Designation provides statutory backing to the rules of the settlement system and 2 provides additional legal certainty to settlements effected through those systems . The NZClear system is operated by the Reserve Bank. The Reserve Bank’s Financial Services Group (“FSG”) is responsible for the administration of the operational aspects of the System. FSG is headed by Mike Wolyncewicz, the Reserve Bank’s Chief Financial Officer, and day-to-day operational support is provided by the Payment and Settlement Services Team within FSG that is managed by the Payments and Settlement Services Manager, Nathan Lewer. FSG reports on the operation of NZClear to Mr Geoff Bascand, Deputy Governor and Head of Operations. The Reserve Bank’s Knowledge Services Group (“KSG”) supports the telecommunications network and 2 Reserve Bank of New Zealand (Designated settlement system – NZClear) Order 2012. 7 related security features utilised by the System. Software support, software development and operational support services are provided by Datacom Systems (Wellington) Limited (“Datacom”). The Reserve Bank manages Datacom’s provision of services through a services contract and related service level agreement. The management process includes assessment of performance at monthly review meetings, monthly performance reports, review of problem management reports, a relationship governance committee and relevant project steering committees. All securities beneficially owned by members and lodged into the System are registered in the name of New Zealand Central Securities Depository Limited (“NZCSD”), which is a wholly-owned subsidiary of the Reserve Bank. NZCSD operates as a bare trustee and is the custodian for securities beneficially owned by members of NZClear. NZClear service iv ed The Reserve Bank is the operator of the NZClear system. The Reserve Bank provides services to members of NZClear in accordance with the NZClear Rules (“the Rules”) dated 1 March 2012. The NZClear system allows members of that System to: 1. Hold their debt and equity securities in their securities accounts within the System, with the securities held for members at the relevant securities registries in the name of NZCSD, which has been ch appointed custodian trustee. 2. Record cash transactions in cash accounts which are provided to members by their relevant clearing Ar bank. 3. Record in members’ securities accounts and cash accounts, the settlement of sales and purchases of securities transactions and cash transfers in accordance with members’ instructions. The Rules provide that once a transaction is settled, the settlement is irrevocable. 4. Give instructions to the Reserve Bank to deal with securities. This includes lodging securities into the System, uplifting securities from the System and issuing instructions to effect corporate actions relevant to the securities. Corporate actions include receiving interest and dividend revenue from securities and the processing of a range of other entitlements associated with ownership of securities, such as rights issues, bonus issues, takeover offers, dividend reinvestment plans, stock conversions and other like events. 5. Use a function known as “FINEWISS” to create and issue fixed interest securities. Members who use this service enter into a “FINEWISS Registry Agreement” with the Reserve Bank. Under that arrangement, the Reserve Bank is the registrar for the relevant securities and uses the NZClear system for that purpose, with NZCSD being the sole registered holder of those securities. 8 Members submit instructions to the System via electronic means, primarily through one or more of the dedicated telecommunications networks (the internet or the SWIFT system). In all cases the System has security features in place designed to ensure that access is authorised and instructions received are authenticated. In the case of corporate actions, processing involves giving instructions either through the NZClear system, or in the case of more complex events, through manual communications. SWIFT is a secure system through which authorised NZClear members communicate in real time and transmit messages including settlement instructions. The operation of NZClear includes elements of the administration of the SWIFT system which are the responsibility of the Reserve Bank. This includes servers on which the Reserve Bank’s interface to SWIFT resides, SWIFT system administration and security including allocation of user privileges to Reserve Bank staff, change control of elements of SWIFT software, administration of the SWIFT system so that authenticated SWIFT messages from authorised members’ are accepted for processing by NZClear, backing up data, business continuity readiness and problem management. In most other respects, reliance is placed on the SWIFT organisation itself for operation of that iv ed System. The contractual relationships between all members, and between the Reserve Bank and all members, are governed by the Rules. The NZClear system produces a range of reports which are generated either on request or automatically. ch The main reports include those which list: securities held in the System (and registered in NZCSD’s name) for a member together with details of securities transactions posted to members’ securities account(s); details of cash transactions that have been posted to a member’s cash account with their clearing Ar bank (the Participating ESAS Account Holder) which are recorded in the NZClear system; details of cash transactions for each clearing bank (the Participating ESAS Account Holder) which are recorded in the NZClear system in respect of each member; and the status of transactions during the transaction lifecycle. During the year ended 30 June 2014 there have been no major upgrades to the functionality provided by the NZClear system. The Reserve Bank interacts with members in several ways. A regular newsletter is emailed to every member, an annual report on the NZClear system is published, a User Advisory Committee is elected and meets with Reserve Bank management four times each year, a user meeting is held every six months, a customer survey is conducted every year and the results are reported back to the User Advisory Committee and members, and Reserve Bank management will meet with individual members (and with clients of members) from time to time. 9 Risk management The internal controls of NZClear are audited each year by Chris Barber with the assistance of PricewaterhouseCoopers (“PwC”), as required by the NZClear Rules, who act on behalf of the Reserve Bank’s external auditor, the Auditor-General (“the Auditor”). The scope of this audit includes the controls performed by the Reserve Bank’s third party independent service provider, Datacom. In addition, the NZClear Rules require that the auditor will undertake a quarterly limited procedures review of key securities reconciliations and report on their findings. The annual report on NZClear controls and the limited procedures reviews of key reconciliations are reviewed by the Reserve Bank’s Audit Committee, with external auditors, Reserve Bank governors and management in attendance. NZClear is also subject to internal audit by the Reserve Bank’s Audit Services division. The main elements of risk management for NZClear entail: reconciliations are performed and reviewed daily; procedures and controls are adhered to; measures to manage operational risk, as described below; and business continuity plans are in place and tested regularly. iv ed ch Managing operational risk in the Reserve Bank is seen as an integral part of day-to-day operations. Operational risk management includes Bank-wide corporate policies that describe the standard of conduct required of staff, a number of mandated requirements (e.g. a project management template), and specific internal control systems designed around the particular characteristics of various Reserve Bank activities. Ar Operational risk management is supported by: an induction programme for new employees that makes them aware of the requirements; monthly reporting to joint regulators including attestations by Reserve Bank management that the conditions of designation for NZClear have been complied with; a quarterly management affirmation by the Chief Financial Officer that corporate policies and departmental internal control systems have been complied with; a proactive problem management process whereby problems and incidents are reported internally and also to the joint regulators and analysed for potential risk management improvements; periodic review of risks and internal controls; and an active internal audit function. In addition to administering system controls the Reserve Bank commissions a third party to undertake reviews of system security with a view to improving system security. 10 Information Technology activities outsourced to a service organisation Within the Information Technology (“IT”) processes described above, specific responsibilities supporting NZClear have been outsourced to a third-party IT service organisation, Datacom Systems (Wellington) Limited (“Datacom”). The significant activities and controls undertaken by Datacom include: Security: User administration of the operating system and database is performed by Datacom on approval by the client account manager of the Reserve Bank. Datacom manage a data centre in Auckland that houses the computer equipment on which the system operates. Environmental and physical security controls over this equipment are operated by Datacom. The Reserve Bank also houses computers in Wellington on which the system operates. Datacom are also responsible for ensuring they have appropriate technical personnel available to Change control: iv ed restore and move production between the Wellington and Auckland sites. Development of software changes is performed by Datacom staff on the approval of a change elaboration document approved by the Reserve Bank. Initial testing of software changes is performed by Datacom before the Reserve Bank’s user testing and subsequent implementation. Implementation of software changes to the production system is performed by authorised Datacom ch staff when authorised by the Reserve Bank. A backup of the System and a back-out plan is prepared by Datacom before any implementation of Operations: Ar program changes. The Reserve Bank uses an online monitoring web-portal (Nagios) to ensure that the System is operating adequately and automated processes and controls have been completed successfully. For example, the portal monitors data backups, system usage and performance processing statistics. On a monthly basis, the controls and services performed by Datacom are required to be assessed and reported to the Reserve Bank. For example, Datacom reports that administrator accounts on the System have been accessed appropriately and relate to authorised work. A monthly meeting is also held between Datacom and the Reserve Bank to discuss management and operation of the System. 11 Members’ controls The controls described in Section IV cover only a portion of the overall internal controls for each member. Achievement of each of the control objectives will also be dependent on members maintaining an effective control environment through implementing controls such as: Documented policies and procedures (including transaction processing procedures, risk management policies such as conditions and restrictions for System use, good password practices, software copyright restrictions and virus protection); Restricted access to operating systems, applications, databases and underlying records (including role-based security mechanisms); User administration management; Transaction processing, authorisation, monitoring and reporting mechanisms; Segregation of duties in transaction processing; Reconciliation of transactions and holdings; Physical security of system infrastructure; Provisions of data backup and restoration and other computer operations; and Business continuity planning. iv ed This report expressly excludes consideration by the Reserve Bank, and the Auditor of the effectiveness of ch members’ own internal controls as distinct from internal control objectives and key controls of the NZClear Ar system, which are the responsibility of the Reserve Bank. 12 Section IV NZClear control objectives A summary of the control objectives relevant to the NZClear System are listed below. Following these are the specific key controls that are designed and implemented to achieve these stated control objectives. Section 1 – Security 1. NZClear security management procedures and application controls are adequate. 2. The Bank’s internal and external network is adequately secured. 3. Access to system privileges within the underlying operating system is adequately secured. 4. NZClear functionality is only available to appropriate users at appropriate levels. 5. Access to the underlying database is adequately secured. iv ed 6. Adequate environmental and physical security controls are in place over computing equipment. Section 2 – Member Detail Administration 1. Authorisation is obtained for all additions, changes and deletions to member details. 2. Additions, changes and deletions to member details are correctly input into the System. ch Section 3 – Application Controls 1. All lodgements and uplifts from the various registries are processed completely, accurately and in a timely manner. Ar 2. Errors in performing lodgements and uplifts are identified and corrected in a timely manner. 3. NZClear holdings are complete and accurate. 4. Corporate actions are completely and accurately processed. Section 4 – Change Control 1. Changes migrated into production are tested and approved. 2. Emergency changes migrated into production are appropriate and authorised. Section 5 – Problem Management 1. Problems are identified and resolved in a timely manner. Section 6 – Backup and Recovery 1. Adequate processes are in place for data recovery. 2. Timely recovery of business operations is possible. 3. System issues over NZClear system are identified and resolved in a timely manner. 13 Section 7 – SLA Monitoring 1. Third party service levels are monitored to ensure compliance with agreed contractual requirements. Section 8 – Period End Processing Ar ch iv ed 1. End of day processing is complete, accurate and timely. 14 Independent assurance report on the description of controls, their design and operating effectiveness To the Governor, Reserve Bank of New Zealand Scope In accordance with the terms of our engagement letter dated 6 November 2013, we were engaged to 0 June 2014, and on the design and operation of controls related to the control objectives stated at controls performed by an independent service provider, Datacom Systems (Wellington) Limited iv ed specified in the description can be achieved only if complementary member controls contemplated in related controls at the Reserve Bank. We have not evaluated the suitability of the design or operating effectiveness of such member controls. ch The Reserve Bank and Datacom are responsible for: preparing the description at Section III and accompanying assertion at Section II, including the completeness, accuracy and method of presentation of the description and assertion; providing the services covered by the description; stating the control objectives in Section IV; and designing, implementing and effectively operating controls to achieve the stated control objectives. Ar operation of controls related to the control objectives stated in that description, based on our procedures. We conducted our engagement in accordance with International Standard on Assurance by the External Reporting Board. That standard requires that we comply with relevant ethical requirements and plan and perform our procedures to obtain reasonable assurance about whether, in all material respects, the description is fairly presented and the controls are suitably designed and operating effectively. An assurance engagement to report on the description, design and operating effectiveness of controls at a service organisation involves performing procedures to obtain evidence about the disclosures in f its System, and the design and operating effectiveness of controls. The procedures selected depend on our judgement, including the assessment of the risks that the description is not fairly presented, and that controls are not suitably designed or operating effectively. Our procedures included testing the operating effectiveness of those controls that we consider necessary to provide reasonable assurance that the control objectives stated in the description were achieved. An assurance engagement of this type also includes evaluating the overall presentation of the description, the suitability of the objectives stated therein, and the suitability of the criteria specified by the service organisation and described in Section II. Also, we did not evaluate the security and controls over the electronic publication of this report. PricewaterhouseCoopers, 113-119 The Terrace, PO Box 243, Wellington 6140, New Zealand T: +64 4 462 7000, F: +64 4 462 7001, pwc.co.nz We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. Limitations of controls at a service organisation and their auditors and may not, therefore, include every aspect of the System that each individual member may consider important in its own particular environment. In addition to this, because of their nature, controls at a service organisation may not prevent or detect all errors or omissions in processing or reporting transactions. Section III also indicates that certain control objectives specified in the description can be achieved only if complementary member controls contemplated in the design controls at the Reserve Bank. Further, the projection of any evaluation of effectiveness to future periods is subject to the risk that controls at a service organisation may become inadequate or fail. iv ed Opinion Our opinion has been formed on the basis of the matters outlined in this report. The criteria we used in assertion at Section II. In our opinion, formi together with the complementary member controls referred to in the scope paragraph of this report, in all material respects: Ar ch (a) The description fairly presents the System as designed and implemented throughout the year ended 30 June 2014. (b) The controls related to the control objectives stated in the description were suitably designed throughout the year ended 30 June 2014. (c) The controls tested, which were those necessary to provide reasonable assurance that the control objectives stated in the description were achieved, operated effectively throughout the year ended 30 June 2014. Description of tests of controls The specific controls tested and the nature, timing and results of those tests are listed in Section VII. Intended users and purpose of the report This report and the description of tests of controls in Sections IV and VII are intended only for members who have used the NZClear system during the year ended 30 June 2014, and their auditors, who have a sufficient understanding to consider it, along with other information including information about controls operated by members themselves, when assessing the risks of material misstatements rts/statements. Our audit was completed on 28 July 2014. This is the date at which our opinion is expressed. Chris Barber On behalf of the Auditor-General Wellington, New Zealand PricewaterhouseCoopers Section VI Definition of testing terms The following are definitions of the terms used in the testing of key controls. 1. Enquiry: Enquired of appropriate personnel. Conducted enquiries seeking relevant information or representations from personnel, performed to obtain, among other things: - Knowledge, additional information and affirmation regarding the control of procedures. 2. Inspection: iv ed - Corroborating evidence of the controls. Inspected documents and records indicating performance of the controls. This may include, among other things: - Inspection of reconciliations and management reports that age and/or quantify reconciling items to assess whether balances and reconciling items appear to be properly monitored, controlled and resolved on a timely basis, as required by the related control. ch - Examination of source documentation and authorisations related to selected transactions processed. Ar - Examination of documents or records for evidence of performance, such as the existence of initials or signatures. - Inspection of the Reserve Bank’s systems documentation, such as operations, manuals, flow charts and job descriptions. 3. Observation: Observed the application or existence of specific controls as represented. 4. Re-performance: Re-performed the control or processing application of the controls to check the accuracy of their operation. This may include, among other things: - Obtaining evidence of the arithmetical accuracy and correct processing of transactions by performing independent calculations. - Re-performing the matching of various system records by independently matching the same records and comparing reconciling items to reconciliations prepared by the Reserve Bank. 17 Section VII Auditor’s tests of operating effectiveness of key controls Se c tion 1 – Se c urity ControlO b je c tive 1 NZClear security management procedures and application controls are adequate. Ref Key Controls PwC Testing Results a) Procedures are in place for the creation and deletion of user accounts. Enquiry and Inspection No exceptions noted. iv ed Confirmed with management that a user administration policy exists for the creation and addition of users. Inspected user listings to confirm new and terminated users processed during the period 1 July 2013 – 30 June 2014 were appropriately approved. d) Inspection Administrator access in the application is appropriately restricted to users in line with business requirements. Inspection System education and training programs have been established and undertaken. Enquiry and Inspection ch c) No exceptions noted. Password parameters and login settings in the application are appropriate and comply with good practice. Inspected password parameters on the NZClear application and noted that passwords complied with good practice. Ar b) No exceptions noted. Inspected a user access listing and confirmed administrator access was restricted to appropriate users based on their role and responsibilities. Confirmed with management that all new employees are involved in an induction process prior to using the System. Inspected the Reserve Bank’s security policies. Inspected security declaration signoffs for a sample of employees. Inspected a sample of quarterly management affirmations to confirm employees were aware and have complied with security policies. 18 No exceptions noted. ControlO b je c tive 2 The Reserve Bank’s internal and external network is adequately secured. Ref Key Controls PwC Testing a) Members must agree and sign the NZClear rules to abide by the Reserve Bank’s network and access rules. Inspection The Reserve Bank network topology is documented to ensure appropriate security mechanisms are in place. Inspection Only Reserve Bank staff can configure the routers supplied to members. Observation and Inspection c) No exceptions noted. Inspected a sample of new members added during the period ensuring a copy of the Reserve Bank’s network and access rules had been signed. No exceptions noted. Inspected the Reserve Bank network diagram to ensure appropriate security mechanisms are in place such as firewalls. No exceptions noted. Observed that access was restricted to authorised users through two factor authentication. iv ed b) Results Inspected the list of users who are able to configure to routers and assessed the appropriateness of access. Inspected router settings that limit configuration access to the Reserve Bank operations team. Annually, the Reserve Bank performs a network security review. Vulnerabilities are identified and reviewed by senior management. Enquiry and Inspection No exceptions noted. ch d) Enquired with management that an independent third party was engaged to perform a network security review on behalf of the Reserve Bank. e) Ar Inspected evidence of the review and reporting of key findings. Confirmed through inspection that identified vulnerabilities were reviewed by management. Network security is regularly reviewed. Inspection Exception noted: For a sample of weeks, inspected evidence of weekly network security reviews identifying potential network vulnerabilities. Evidence of scans was not accessible for periods prior to September 2013. Reserve Bank Response: With a move to a new solution for scanning network security, this matter has now been resolved. 19 ControlO b je c tive 3 Access to system privileges within the underlying operating system is adequately secured. Ref Key Controls PwC Testing Results a) Access to system privileges at the operating system level requires manager approval. Enquiry and Inspection No exceptions noted. Confirmed with Datacom that all new users must be approved by a manager at Datacom or the Reserve Bank. Inspected a sample of approvals of new users added during the period. Password parameters and login settings at the operating system level are appropriate and comply with good practice. Inspection Privileged access to the operating system is logged and reviewed. Inspection No exceptions noted. Inspected a listing of all administrator users and confirmed with management that their access was appropriate. No exceptions noted. iv ed d) Inspection Obtained and inspected the operating system password settings and noted that passwords complied with good practice. No exceptions noted. Inspected a sample of monthly SLA reports that confirmed direct access to the operating system is logged and reviewed. ch c) Administrative access to the operating system is appropriately restricted. Ar b) 20 ControlO b je c tive 4 NZClear functionality is only available to appropriate users at appropriate levels. Ref Key Controls PwC Testing Results a) Administrator access in the application is appropriately restricted to users in line with business requirements. Inspection No exceptions noted. User accounts and access rights are reviewed regularly to ensure that these are appropriate. Inspection No exceptions noted Inspected a sample of the monthly user account reviews conducted over the user accounts and rights allocated. iv ed b) Inspected a user access listing and confirmed administrator access was restricted to appropriate users based on their role and responsibilities. ControlO b je c tive 5 Access to the underlying database is adequately secured. Key Controls PwC Testing a) Access to system privileges at the database level requires manager approval. Results ch Ref Enquiry and Inspection No exceptions noted. Ar Confirmed with Datacom that all new users must be approved by a manager at Datacom or the Reserve Bank. Inspected a sample of approvals of new users added during the period. b) c) d) Privileged user accounts at the database level are regularly reviewed for appropriateness. Inspection Password parameters and login settings at the database level are appropriate. Inspection Privileged access to the database is logged and reviewed. Inspection No exceptions noted. Obtained and inspected a sample of user accounts reviews at the database level. No exceptions noted. Obtained and inspected the database password settings and noted that passwords complied with good practice. No exceptions noted. Inspected a sample of monthly SLA reports in which the third party vendor reports access over the database. 21 ControlO b je c tive 6 Adequate environmental and physical security controls are in place over computing equipment. Ref Key Controls PwC Testing Results a) Environmental and physical security controls are in place over computing equipment. Observation No exceptions noted. Observed during a walkthrough of the Wellington and Auckland sites that: Access to the premises and computing equipment is physically locked and not publicly accessible Electronic swipe cards are required to access the premises and computing equipment Environmental controls are in place in the server rooms, including: o air conditioning units; raised floor; o dry pipe sprinkler system; o fire extinguisher; o fire alarms; o racks for all equipment; o UPS systems; and o backup generators. Ar ch iv ed o 22 Se c tion 2 – M e m b e rDe ta ilAd m inistra tion ControlO b je c tive 1 Authorisation is obtained for all additions, changes and deletions to member details. Ref Key Controls PwC Testing Results a) New members are assessed for eligibility prior to being accepted as an NZClear member. Inspection No exceptions noted. Inspected the new member addition procedures document. For a sample of new members added during the period inspected evidence of assessment for eligibility prior to the member being accepted. Inspection No exceptions noted. If a change is to a member's clearing bank or account number, NZClear personnel will only act if the new clearing bank confirms it is acting for the member and, in the case of a new account number, a deposit slip is provided. Enquiry and Inspection For a sample of new members added during the period inspected evidence of sign-off by the Manager of NZClear and CFO. iv ed c) Approval for new members is required from the Manager of NZClear and Chief Financial Officer (CFO). No exceptions noted. Inspected the amending current member procedures document. Confirmed with management a change in the bank account must be confirmed with the new clearing bank and, in the case of a new account number, confirmed to a deposit slip. ch b) d) Ar For a sample of bank account changes, inspected the confirmation letter was received by the clearing bank. A request for deletion must be authorised by the member. Inspection No exceptions noted. Inspected the deleting existing member procedures document. For a sample of deletions during the period, inspected evidence of authorisation by the member before deletion. e) All changes to member details are subject to a peer review process. Enquiry and Inspection Inspected the amending current member procedures document. Confirmed with management that all changes to member details must be peer reviewed. For a sample of changes to member details, inspected the documentation to ensure they had been peer reviewed. 23 No exceptions noted. ControlO b je c tive 2 Additions, changes and deletions to member details are correctly input into the System. Ref Key Controls PwC Testing Results a) A documentation checklist is completed to confirm that all of the required forms have been received for new members. Inspection No exceptions noted. All changes to member details are subject to a peer review process. Enquiry and Inspection b) For a sample of new members added during the period inspected the documentation checklists to ensure that all required forms had been received and peer reviewed. No exceptions noted. Inspected the amending current member procedures document. Confirmed with management that all changes to member details must be peer reviewed. Enquiry and Inspection Inspected the amending current member procedures document. Confirmed with management a change in the bank account must be confirmed with the new clearing bank and, in the case of a new account number, confirmed to a deposit slip. ch If a change is to a member's clearing bank or account number, NZClear personnel will only act if the new clearing bank confirms it is acting for the member and, in the case of a new account number, a deposit slip is provided. For a sample of bank account changes, inspected the confirmation letter was received from the clearing bank. Ar c) iv ed For a sample of changes to member details, inspected the documentation to ensure they had been peer reviewed. 24 No exceptions noted. Se c tion 3 – Applic a tion c ontrols ControlO b je c tive 1 All lodgements and uplifts from the various registries are processed completely, accurately and in a timely manner. Ref Key Controls PwC Testing Results a) Processes and procedures are documented and current. Inspection No exceptions noted. Lodges and uplifts completed manually are independently reviewed. Inspection Where the lodge or uplift is performed automatically, the System accurately and completely settles the lodge or uplift at the registry. Observation d) iv ed For a sample of lodges and uplifts completed manually inspected evidence of independent review and sign-off. No exceptions noted. For a sample of lodges and uplifts processed automatically traced the completion of each lodge and uplift to the registry to ensure that it had settled correctly. ch c) No exceptions noted. Rejection of lodges and uplifts via the Registry Interface and NZX Interface are reported to NZClear operator. Observation Observed onscreen the tracking of lodges and uplifts and noted that any lodges and uplifts that have failed were highlighted to the NZClear operator. Ar b) Inspected the lodges and uplifts procedure documentation for both manual and automated processes. Noted that each procedure covered the relevant steps to complete a lodge or uplift. 25 No exceptions noted. ControlO b je c tive 2 Errors in performing lodgements and uplifts are identified and corrected in a timely manner. Ref Key Controls PwC Testing Results a) Lodges and uplifts completed manually are independently reviewed. Inspection No exceptions noted. Regular reconciliations are prepared reconciling the number of securities in the NZClear system and those held in various registries under the name of NZCSD. These are peer reviewed with discrepancies followed up immediately. Inspection Exception noted For a sample of reconciliations inspected evidence that registry holdings were reconciled to NZClear. Inspected evidence of peer review and discrepancy resolution. For one sampled reconciliation evidence of independent peer review was not available. This reconciliation was reviewed as a part of the weekly reconciliation reports. iv ed b) For a sample of lodges and uplifts completed manually inspected evidence of independent review and sign-off. Reports on reconciliations are reviewed by senior management on a weekly basis to review completion and nature of any occurring problems. Inspection For a sample of weeks inspected evidence of sign off by management to confirm that they had reviewed and confirmed that the reports on reconciliations had been prepared and problems followed up. Ar c) ch Reserve Bank Response: 26 All staff have been reminded of the second level check requirement and further emphasis placed on weekly assessment to identify any failings in the daily reconciliations process. No exceptions noted. ControlO b je c tive 3 NZClear holdings are complete and accurate. Ref Key Controls PwC Testing Results a) Regular reconciliations are prepared reconciling the number of securities in the NZClear system and those held in various registries under the name of NZCSD. These are peer reviewed with discrepancies followed up immediately. Inspection Exception noted For a sample of reconciliations inspected evidence that registry holdings were reconciled to NZClear. Inspected evidence of peer review and discrepancy resolution. For one sampled reconciliation evidence of independent peer review was not available. This reconciliation was reviewed as a part of the weekly reconciliation reports. Reserve Bank Response: Inspection No exceptions noted. For a sample of weeks inspected evidence of sign-off by management to confirm that they had reviewed and confirmed that the reports on reconciliations had been prepared and issues resolved. ch Reports on reconciliations are reviewed by senior management on a weekly basis to review completion and nature of any occurring problems. Ar b) iv ed All staff have been reminded of the second level check requirement and further emphasis placed on weekly assessment to identify any failings in the daily reconciliations process. 27 ControlO b je c tive 4 Corporate actions are completely and accurately processed. Ref Key Controls PwC Testing Results a) Processes and procedures are documented and current. Inspection No exceptions noted. A check-sheet is completed for every corporate action and peer reviewed independently. Inspection A second person is responsible for checking the diary of actions. Enquiry and Inspection For a sample of corporate actions, inspected evidence that a check-sheet was completed and an independent peer review performed. No exceptions noted. iv ed Confirmed with management that at least two people are responsible for updating the corporate action diary in the corporate actions checklist. For a sample of weeks inspected evidence of sign off by management to confirm that they had reviewed and confirmed that the diary of actions had been reviewed by two people. ch c) No exceptions noted. Ar b) Inspected the corporate actions procedure documentation. Noted that each procedure covered the relevant steps to complete each type of corporate action event. 28 Se c tion 4 – Cha ng e Control ControlO b je c tive 1 Changes migrated into production are tested and approved. Ref Key Controls PwC Testing Results a) Documented change control procedures are in place that require authorisation by multiple persons for all changes. Inspection No exceptions noted. A central database is in place to record all change requests. Enquiry and Observation b) Inspected the documented change control procedures and workflows. Confirmed with management that these are current. No exceptions noted. Enquired of management to confirm that all changes are logged within a central application. c) Separate development, test and production environments are used. iv ed Observed the central application and noted the change details were logged in the application. Inspection No exceptions noted. Inspected evidence to confirm that separate development, test and production environments exist. Appropriate segregation of duties exists throughout the change management process. Inspection Changes are authorised prior to development. Inspection Changes cannot be released into production unless they are tested. Inspection Changes cannot be released into production unless they have been authorised by the required personnel. Inspection No exceptions noted. For a sample of changes released, inspected evidence that there were multiple staff members involved in each stage of the process, including development, testing and authorisations. Ar d) ch For a sample of months, inspected evidence confirming that deployments to the production environment were monitored. e) f) g) No exceptions noted. For a sample of changes released during the period obtained evidence of authorisation prior to the change being developed. No exceptions noted. For a sample of changes released during the period obtained evidence of testing prior to the change being implemented. No exceptions noted. For a sample of changes released during the period obtained evidence of authorisation prior to the change being implemented. 29 Ref Key Controls PwC Testing Results h) Third party vendors are monitored to ensure they have appropriate controls in place, and that the procedures are followed to develop, test, review and implement changes. Inspection No exceptions noted. Inspected the Service Level Agreement and noted that service offerings by Datacom are adequately addressed. Confirmed that Change Management is supported by Datacom. For a sample of months, inspected the monthly reports provided by Datacom to the Reserve Bank which reports on KPIs and Datacom’s obligations, including Change Management procedures. For a sample of months, inspected the minutes from meetings held between the Reserve Bank and Datacom. Inspection No exceptions noted. iv ed For a sample of changes released during the period, inspected evidence that back-out plans had been prepared. ch Back-out plans are prepared for all changes prior to migration where appropriate. Ar i) 30 ControlO b je c tive 2 Emergency changes migrated into production are appropriate and authorised. Ref Key Controls PwC Testing Results a) Emergency changes are authorised before implementation. Inspection No exceptions noted. First Aid (a defined user account for the migration of emergency changes) log is authorised and documented for all emergency changes. Inspection b) For a sample of emergency changes released during the period obtained evidence of approval by senior NZClear team members prior to implementation. No exceptions noted. For a sample of emergency changes released during the period, reviewed the authorisation and documentation for the use of the First Aid account and the emergency change. Inspection No exceptions noted. Inspected the Service Level Agreement and noted that service offerings by Datacom are adequately addressed. Confirmed that Change Management is supported by Datacom. ch Third party vendors are monitored to ensure they have appropriate controls in place, and that the procedures are followed to develop, test, review and implement changes. For a sample of months, inspected the monthly reports provided by Datacom to the Reserve Bank which reports on KPIs and Datacom’s obligations, including Change Management procedures. Ar c) iv ed Inspected the Change log to confirm that all emergency changes were promoted as a First Aid change. For a sample of months, inspected the minutes from meetings held between the Reserve Bank and Datacom. 31 Se c tion 5 – Prob le m M a na g e m e nt ControlO b je c tive 1 Problems are identified and resolved in a timely manner. Ref Key Controls PwC Testing Results a) Proactive Problem Management (PPM) processes and procedures are documented. Inspection No exceptions noted. A PPM form is completed for each problem encountered, outlining a description of the problem, consequences of the problem, cause of the problem and the actions taken to remedy the problem. Inspection All PPMs are subject to review by the Chief Financial Officer. Inspection iv ed Inspected a sample of PPMs raised in the period related to NZClear and verified that it was completed in detail including a description, consequences, cause and actions taken to remedy the problem. Reviewed the PPM register and the NZClear operational issues log to confirm that problems and issues logged from 1 July 2013 to 30 June 2014 had not impacted the control objectives under review. No exceptions noted. Inspected a sample of PPMs raised in the period and obtained the PPM form and confirmed that all sampled PPM’s were signed off by the CFO and forwarded to a Governor when relevant. ch c) No exceptions noted. Ar b) Inspected the PPM policy document and noted that it covered the process for logging and resolving a PPM. 32 Se c tion 6 – Ba c kup & Re c ove ry ControlO b je c tive 1 Adequate processes are in place for data recovery. Ref Key Controls PwC Testing Results a) Data backup and restore procedures are in place. Enquiry and Inspection No exceptions noted. Daily backups are scheduled to occur automatically. Inspection: No exceptions noted. Inspected the web portal used for the monitoring of backups to confirm that the portal is configured for backups to occur multiple times per week. Confirmed that an automatic alert is raised when a backup related incident occurs. iv ed b) Confirmed with management that system backup and operator restore procedures are in place. Inspected the backup and restore procedures, confirming they are current. Inspected a sample of backup related incidents that have been reported to the service desk to confirm that they had been investigated and resolved. Inspection No exceptions noted. For a sample of months inspected evidence to confirm that data restorations had been completed. ch Regular tests of data restoration are undertaken. Ar c) 33 ControlO b je c tive 2 Timely recovery of business operations is possible. Ref Key Controls PwC Testing Results a) An up-to-date business continuity plan is in place. Inspection No exceptions noted. Technically trained persons are available for restoration of Systems. Enquiry and Inspection b) Inspected the Business Continuity plan last updated in May 2014 confirming that it was relevant and current. No exceptions noted. Confirmed with management and Datacom that operational staff at the Reserve Bank and at Datacom have sufficient training to conduct System restores. c) Redundant equipment (including a fully operational alternative site) is available for restoration purposes. iv ed Inspected evidence to confirm that a switchover process had occurred during the period, which alternates processing between the Auckland and Wellington sites. Enquiry and Inspection No exceptions noted. Confirmed with management that there are two identical sites in both Auckland and Wellington to support NZClear operations. UPS for all critical systems are maintained and tested on a regular basis. Observation and Inspection No exceptions noted. Ar d) ch Inspected evidence to confirm that a switchover process had occurred during the period, which alternates processing between the Auckland and Wellington sites. During a walkthrough of the Auckland and Wellington server rooms observed that UPS facilities are available. Obtained and inspected a sample of UPS test reports performed during the period. e) Backup power generators are available and tested on a regular basis. Inspection No exceptions noted. Obtained and inspected a sample of the backup power generators being tested during the period. 34 ControlO b je c tive 3 System issues over NZClear system are identified and resolved in a timely manner. Ref Key Controls PwC Testing Results a) A data centre monitoring system, via a web portal, is used to monitor automated processes and generates alerts on a priority basis for issues relating to filesystem usage, disk space, backups, batch processes and other key metrics. Failures are identified and managed to resolution. Observation and Inspection No exceptions noted. Automatic alerts are paged to support personnel when the System self-diagnoses unexpected conditions. Enquiry and Observation Inspected a sample of identified failures to ensure that they had been investigated and resolved. iv ed Inspected a sample of months for evidence confirming the Reserve Bank had received all system related failures that had occurred as part of the monthly Services Agreement reporting process. Confirmed with management that alerts are generated for unexpected conditions. Observed an example of an alert sent to the Operations team email account. ch Inspected the alert settings on the system showing the conditions being monitored and alerts being sent. Ar b) Inspected the web portal used for monitoring key metrics to confirm that an automatic alert is raised when an incident occurs. 35 No exceptions noted. Se c tion 7– SLA M onitoring ControlO b je c tive 1 Third party service levels are monitored to ensure compliance with agreed contractual requirements. Ref Key Controls PwC Testing Results a) An service agreement is in place between third parties and the Reserve Bank for the management of the NZClear environment. Enquiry and Inspection No exceptions noted. A monthly meeting is held between the Reserve Bank and third parties to discuss any issues with the environment and ensure compliance with contractual requirements. Inspection Third party reports are performed detailing any issues during the month and reporting against KPIs as detailed in the service agreement. Inspection iv ed For a sample of months, inspected the minutes from meetings held between the Reserve Bank and Datacom. No exceptions noted. For a sample of months, inspected the monthly reports provided by Datacom to the Reserve Bank which reports on KPIs and Datacom’s obligations and inspected for reporting on the obligations per the service agreement. ch c) No exceptions noted. Ar b) Confirmed with management that a service agreement is in place with Datacom. Obtained and inspected the agreement and noted that service offerings by Datacom are adequately addressed. 36 Se c tion 8 – Pe riod End Proc e ssing ControlO b je c tive 1 End of day processing is complete, accurate and timely. Ref Key Controls PwC Testing Results a) The nightly close reports list the automated processes that have run and whether each process has completed successfully. Failures are identified and managed to resolution. Inspection No exceptions noted. Inspected for the period 1 July 2013 to 28 March 2014 the nightly close reports and confirmed that the automated processes are identified in the report. iv ed For the period 1 July 2013 to 28 March 2014, inspected for a sample of days the Operations Checklist that checks the nightly close reports to confirm the automated processes have been completed successfully. Where a failure was identified, confirmed that appropriate resolution/escalation procedures were followed through follow-up narrations on the nightly close reports. Operations Checklists are used to monitor processing. Inspection No exceptions noted. For the period 1 July 2013 to 28 March 2014 a sample of days inspected the Operations Checklist to ensure that all operational activities were performed. Ar b) ch Confirmed that subsequent to 28 March 2014, a new system for system monitoring was implemented as validated within control procedure (c). Confirmed that the Checklist was reviewed for any failures and resolution actions taken were appropriate. Confirmed that subsequent to 28 March 2014, a new system for system monitoring was implemented as validated within control procedure (c). c) A data centre monitoring system, via a web portal, is used to monitor automated processes and generates alerts on a priority basis for issues relating to filesystem usage, disk space, backups, batch processes and other key metrics. Failures are identified and managed to resolution. Observation and Inspection Inspected the web portal used for monitoring key metrics to confirm that an automatic alert is raised when an incident occurs. Inspected a sample of identified failures to ensure that they had been investigated and resolved. Inspected a sample of months for evidence confirming the Reserve Bank had received all system related failures that had occurred as part of the monthly Services Agreement reporting process. 37 No exceptions noted.