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Online Transactions – Defining “Normal”
I’ve gotten several inquiries about this since I last posted so I thought I’d better address it. The new FFIEC authentication guidance requires you to conduct periodic risk assessments, and to apply layered controls appropriate to the level of risk. Transactions like ACH origination and interbank transfers involve a generally higher level of risk to…
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Interpreting The New FFIEC Authentication Guidance – 5 Steps to Compliance
We’ve all now had a couple of weeks to digest the new guidance, and what has emerged is a clearer understanding of what the guidance requires…and what it doesn’t. But before we can begin to formulate the specific compliance requirements, we have to interpret what the guidance is actually saying…and what it isn’t. And along…
