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Risk Assessing Internet Banking – Two Different Approaches
One of the big “must do” take-aways from the updated FFIEC Authentication Guidance was the requirement for all institutions to conduct risk assessments. Not just prior to implementing electronic banking services, but periodically throughout the relationship if certain factors change, such as: changes in the internal and external threat environment, including those discussed in the…
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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…
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Corporate account takeovers – responsibility vs. liability
In all remote merchant services (RDC, remote ACH, remote wire origination, etc.) there are three main parties responsible for securing the transaction:
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Top 5 Compliance Trends for 2011 – Part 1
I recently looked back at 2010, and the predictions I made a year ago. This post begins a series of the top regulatory compliance trends for the current year. I’m going to focus on the top 5, and my sources for these are the following: Recent audit and examination experience from our customers Recently released…