We have bill pay and transfer between accounts avail. to custs. on our trans. site. External auditors said to rate these activites medium (trans. just between acccts requires additional pin), and we monitor bill pay amts. for abnormalities...I thought the trend (best practices) call for such trans, to be rated high (that is, that is what the regulators will expect). Have any of you rated your medium???

transfer between owned accounts at the bank would be low or medium depending on the similarity of the vestings (sole to joint would be medium).

bill pay is inherently high risk until AFTER the MFA is implemented.