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Authentication: 2011 FFIEC Supplement and Regulatory Expectations

The FFIEC Supplement to the 2005 Authentication in an Internet Banking Environment was released on June 28, 2011. The supplement, expanding on the original guidance, stresses regulatory expectations for authentication methodologies, layered security, and training for both consumer accounts and business accounts. Among the expectations are periodic risk assessments, controls to detect and respond to suspicious activity, controls over administrator functions, enhanced identification and verification strategies, and more detailed customer awareness education.

While the guidance is focused on Internet Banking risks and management technologies, it is applicable to all forms of electronic banking activities including mobile banking. The supplement also has an appendix that provides an additional discussion on the threat landscape and compensating controls that should be considered. The examiners will start assessing financial institutions under the enhanced authentication expectations January 2012.


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