DDoS attacks have been confirmed that have taken down two credit unions and several large banks' websites. It's been proven our entire financial system is vulnerable. While stealing personal information doesn't seem to have been at play, this is a critical concern for the entire financial services industry. The two confirmed, targeted credit unions were able to get their sites back up in a few hours, which is excellent news. Consider for a moment if these attacks had not been one offs, but a coordinated and concerted effort to take down the U.S.—or even global—banking system. It's not difficult to imagine, raising grave safety and soundness and national security concerns.

If this sounds far-fetched, you're wrong. In 2007 the Estonian government was forced to shut down all access to government websites from IP addresses outside of Estonia when rioting spread from the streets to the virtual highway, according to arstechnica.com. Estonia claimed that the DDoS attack came from Russian government IP addresses. The New York Times website was reportedly attacked by the Chinese government for a period of four months, and it has allegedly gone after other news sites reporting negative news about the government. Cyber warfare with countries, like Iran, where the group taking credit for the DDoS attacks on the credit unions are from, wouldn't be bloody but it could be costly, which could turn bloody.

Meanwhile the Federal Financial Institutions Examination Council is dilly-dallying with consumer disclosures in social media. This is heart-stoppingly out of touch considering the recent cyber attacks. I will state upfront that I have no idea how to prevent a DDoS attack or repairs needed after the fact. I do recognize the need to address this matter promptly as opposed to making sure CD account offerings via Twitter include the appropriate federal deposit insurance logos.