We are interested in hearing whether other banks are offering additional means for MFA for high risk transactions conducted online (i.e., ACH and wires) in conjunction with another form of MFA for transactions with a lower risk (internal transfers, etc.). We are currently using a Passmark system (challenge questions if computer is not registered and an authentication image prior to inputting a password), but are wondering if this form of MFA is "commercially reasonable" considering the risk with ACH Origination and wire transfers.
Thanks for sharing!

Specific discussion on strengths and weaknesses on your banks system would be better discussed in a private forum. Discussion here may have to be general in nature.