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In 2005, the Federal Financial Institutions Examination Council (FFIEC)
issued guidance related to e-banking, �Authentication in an Internet Banking
Environment.� This updated interagency guidance, which replaced the FFIEC's
Authentication in an Electronic Banking Environment, issued in 2001,
specifically addressed the need for risk-based assessment, customer awareness,
and security measures to authenticate customers using a financial institution�s
Internet-based services.
Although this guidance is focused on the risks and risk management techniques
associated with the Internet delivery channel, the principles are applicable to
all forms of electronic banking activities.
The guidance, which banks are expected to have achieved conformance with by
year-end 2006, states that financial institutions should periodically:
- Ensure that their information security program:
- Identifies and assesses the risks associated with Internet-based products
and services;
- Identifies risk mitigation actions, including appropriate authentication
strength; and
- Measures and evaluates customer awareness efforts;
- Adjust, as appropriate, their information security program in light of
any relevant changes in technology, the sensitivity of their customer
information, and internal or external threats to information; and
- Implement appropriate risk mitigation strategies.
Town North Bank has undertaken a risk-based assessment of all electronic
banking systems. During this assessment, we reviewed the threats to those
systems and the existing controls. We found that most systems have adequate
controls and therefore have little to no residual risk.
Here are the key findings of our risk assessment:
- www.tnbonline.com is a low-risk system therefore current controls are
adequate.
- TNB has evaluated our customer awareness program. The following types of
customer communication are provided:
- Customers are provided with information related to e-banking
authentication on www.tnbonline.com. A �security section� has been
established to house relevant information.
- Appropriate communication is provided, as needed, to customers through
the normal communication channels related to e-banking authentication
requirements or guidelines.
- Statement messages related to keeping information secure are scheduled
to be inserted on an annual basis.
- PASSPORT Online Banking with Bill Payment and Cash Manager
products will use a TriCipher solution to be implemented by the end of 2006.
- A committee has been chartered to continue the process of evaluating
our customer awareness program and to ensure that we take a risk-based
assessment of our systems on an annual basis.
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