http://www.greenarmor.com/a-bolwpfrm.shtml

This new white paper explains key human-factors issues in ensuring the effectiveness of mutual/site authentication and two factor authentication, and explains how inappropriately designed two-factor and site/mutual authentication systems can easily be compromised with tricks not much different than those currently employed by online fraudsters.

And if Green Armor's mutual authentication method becomes the de facto standard fraudsters will find a way to comprimise it. The best solution, after meeting the FFIEC guidelines with whatever solution, is to frequently educate customers and drive home the message of online security and protecting their personal information.