Question: I already perform Risk Assessments as required by the FFIEC Handbook. Does this mean that I'm in compliance with the October 2005 FFIEC Guidance "Authentication in and Internet Banking Environment"?
Answer: Unfortunately, no. Banks have been required to perform various risk assessments by current FFIEC IT Handbook procedures, however the Risk Assessment required by this guidance is different. Most banks currently perform an inwardly facing risk assessment that examines threats and vulnerabilities posed to their internal systems by hackers or other unethical individuals. This guidance looks at the possibility that someone can access online (and other electronic) systems by easily posing as a legitimate customer. The risk assessment must be performed on a transaction-by-transaction basis, from the customer access perspective. Key indicators to whether or not a transaction is deemed "high-risk" are the ability to transfer funds or the disclosure of personal non-public information. So in short, this is a new risk assessment which must be performed on all electronic delivery channels that will drive the bank's mitigation strategy. In addition, in order to be fully compliant, the risk assessment must be complete, and the mitigation strategy must be implemented by year-end 2006.
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CC Pace is a financial services consulting firm whose clients include members of the Fortune 100, as well as industry entrants and mid-size firms. CC Pace provides the banking industry the information and services you need to stay competitive in your markets using the best and most secure risk management and mitigation technologies. For additional information please visit our website at www.ccpace.com, call us at 703-631-6600, or email us at info@ccpace.com.
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