The program in question is actually a GNT being called by a CGI.EXE program. We're using that rather than a newer technology because the system was converted from NetExpress 5.0 and has over 100 CGIs, so converting them to something like ASP.NET is a large undertaking. It's on the radar, just down the road a tad.
I'm convinced that the problem is NOT the location of the config file. We tried moving it to multiple locations with no success. The problem appears to be something in the web client is probably using a technology that native cobol web program didn't like, causing the message from the site to the service to get garbled. In any case, we discovered that we could use winHttp, and that works just fine.
Mike