In managing vendors for your institution, what are your first, second and third lines of defense? You can delegate authority, but you cannot delegate responsibility. Responsibility and potential liability rest on the financial institution.
NACHA approved Same-Day ACH to be rolled out over the course of the next three years, with phase one going into effect in September 2016, in response to the need for faster electronic payments and settlement.
Change an online banking password and stop a cyber attack? Not necessarily. It may be closing the barn door after the horses are out. The operational response to a cyber incident must be swift, decisive, effective.