Answer:
I'm not aware of any requirement to notify customers of implementation of multi-factor authentication. The regulatory guidance does suggest that customer education about internet banking risks and measures to mitigate that risk is advisable. It really is a customer service issue. If you don't notify your customers ahead of time, you're going to wind up with a lot more service calls when the customers don't understand what they are seeing or become suspicious that they might not be at the real bank website. The purpose of your notification would be to alert them ahead of time of these changes.
First published on BankersOnline.com 4/09/07