Initial Commentary on the FFIEC Internet Banking Guidance FAQs

STRONG Authentication

The FAQs recently published by the FFIEC on August 15, 2006, is an attempt by the FFIEC to answer questions asked of them about their guidelines on Internet Banking Authentication published October 12, 2005. The 2005 guidelines were an outgrowth of a previous guidance document issued in 2001.

As with all federal level guidance publications, as well as federal level legislation, it is not expedient to recommend specific technologies to solve the problem, whatever that problem is. The problem before the Internet banking industry is one of weak authentication. The problem can be solved in a number of ways with a number of technologies - one way is not recognized to be better than another necessarily. Technology changes and morphs; seemingly at the speed of light, leaving the solutions of 2001 pre-empted by the solutions of 2006.

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