Last year, the Federal Financial Institutions Examination Council (FFIEC) released a much-anticipated supplement to its Authentication in an Internet Banking Environment guidance.  The supplement updates the FFIEC’s supervisory expectations regarding depository institutions’ customer authentication, layered security, and other controls for Internet banking.  Starting this year, FFIEC information technology examinations will include reviews for compliance with the supplement. 

A study released by Guardian Analytics suggests that institutions are moving towards compliance with the supplement but may not be completely prepared for FFIEC IT examinations to be conducted in 2012.  The Guardian Analytics study polled executives at 100 U.S.-based financial institutions in November 2011.  The study found that 43 percent of institutions had not yet completed a risk assessment of online banking, and 41 percent had not developed a plan for addressing online banking security gaps.  Further, 22 percent of institutions had not reviewed the FFIEC supplement.  It is expected that the supplement will be a hot topic throughout 2012 as FFIEC IT examinations reveal the agencies’ stance on the supplement as well as institutions’ compliance with the supplement.    

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Mike Nonaka Mike Nonaka

Michael Nonaka is co-chair of the Financial Services Group and advises banks, financial services providers, fintech companies, and commercial companies on a broad range of compliance, enforcement, transactional, and legislative matters.

He specializes in providing advice relating to federal and state licensing and…

Michael Nonaka is co-chair of the Financial Services Group and advises banks, financial services providers, fintech companies, and commercial companies on a broad range of compliance, enforcement, transactional, and legislative matters.

He specializes in providing advice relating to federal and state licensing and applications matters for banks and other financial institutions, the development of partnerships and platforms to provide innovative financial products and services, and a broad range of compliance areas such as anti-money laundering, financial privacy, cybersecurity, and consumer protection. He also works closely with banks and their directors and senior leadership teams on sensitive supervisory and strategic matters.

Mike plays an active role in the firm’s Fintech Initiative and works with a number of banks, lending companies, money transmitters, payments firms, technology companies, and service providers on innovative technologies such as bitcoin and other cryptocurrencies, blockchain, big data, cloud computing, same day payments, and online lending. He has assisted numerous banks and fintech companies with the launch of innovative deposit and loan products, technology services, and cryptocurrency-related products and services.

Mike has advised a number of clients on compliance with TILA, ECOA, TISA, HMDA, FCRA, EFTA, GLBA, FDCPA, CRA, BSA, USA PATRIOT Act, FTC Act, Reg. K, Reg. O, Reg. W, Reg. Y, state money transmitter laws, state licensed lender laws, state unclaimed property laws, state prepaid access laws, and other federal and state laws and regulations.