This might be an obvious one. When a bank is providing a brochure for customer awareness for Authentication in the Electronic Banking Environment, does the bank need to send all customers a brochure or just the customers signed up for internet banking?

I don't think there is any requirements..this is more a marketing doc rather disclosure or T&Cs

Under the guidance from the FFIEC dated October 12, 2005 it states that a bank "should make efforts to educate their customers" Therefore, our bank has decided to cover the bases on this and buy brochures to make customers aware of the Authentication in the Electronic Banking Environment. So if the bank sends these brochures out, should we send to all customers or just to the customers sighned up for internet banking?

FIs have taken several different approaches. We have provided detailed information on our website, which is used to access the homebanking site and requires the MFA. I really don't see a need to supply to all customers...if you are not an ebanking customer, you won't know what is about anyway.

Isn't a little late anyway? Haven't you going live with MFA??

We purchased some generic brochures on the subject of info security and the net in general and also added some info on our internet site (home page). I know the guidance was specific in that they will be looking for "proof" that you've done something...this always translates to something they can touch or print in my book. You can also mail some stuffers with statements.

We created a brouchure and sent to all current online banking customers prior to going live with MFA. We also have the brochure on our web site. Going forward, customers that sign up for online banking are presented a copy (either at the branch or online) prior to being grated access.

So is there an expectation to provide continous / ongoing awareness training to customers? I know this was big several years back, but what about now?

Is it just good business or is there a strong recommendation?