In June 2011, the FFIEC issuedits Supplement to Authentication in an Internet BankingEnvironment. This was originally met with a great deal ofquestioning and requests for clarity. The dust has now settled, andfinancial institutions are expected to understand the guidanceobjectives and have initiatives in place to addressaccordingly.

I've been working with credit unions to meet the goals requiredof this new guidance for more than two years, and there stillremain many institutions struggling with the FFIEC's memberawareness and education demands. There appears to be a gapbetween providing educational materials to members (business andconsumer) and members acknowledging their receipt and understandingof the materials.

Here are some of the reasons why I believe members may beignoring educational materials:

• The educational material is not compellingRegardless of the distribution method, the material simply fails tocapture members' attention. Credit unions may use multipledistribution channels such as website posts, brochures, statementstuffers, but with the inundation of materials that members receivefrom their financial institutions and hundreds of other sources,educational materials are largely overlooked.
• A strategic communication plan and messaging ismissing Many credit unions fail to create and follow astrategic roadmap for ongoing Member Awareness and EducationProgram initiatives. As a result, messaging begins to lack specificfocus and does not create compelling reasons why members should beattentive to the communications regarding the need for additionalor enhanced technology controls to prevent/detect fraud.
• The Member Awareness and Education Program is stuck onthat “backburner” The Member Awareness and EducationProgram component of the FFIEC guidance is not a priority and otherprojects have taken precedence, leaving enhancements in theconceptual phase. This may become an issue due to expectationsoutlined in the guidance. For instance, the FFIEC guidance advisesthat there are, “certain specific minimum elements that should bepart of an institution's member awareness and education program.”If the credit union's educational program does not include theseitems, then it is opening it up to examiner scrutiny. However,examiner scrutiny should not be the primary reason for enhancingthe educational campaign, there is an enormous opportunity tomitigate fraud.
• Executives are concerned that intentional efforts toencourage education may alienate commercial membersTypically, credit unions do not want to impose on their members bymaking education mandatory. As a result, many commercial membersare falsely under the impression that their accounts are protectedand insured against fraud. In reality, helping a business toprotect against fraud is not an imposition at all, but a service.Focusing on this message will help commercial members realize thevalue and necessity of staying informed and helping to do theirpart.

Next Page: A Few Key Tactics Despite these common pitfalls, I have seen manycredit unions exceeding in their education and complianceinitiatives. Here are a few key tactics to success with theEducation and Awareness Program:

• Leveraging unique delivery channels for communicatingto the higher-risk commercial member This is more than acompliance initiative; it is also an opportunity to buildrelationships. Credit unions are using specific campaignsdesigned to create interest and a desire to learn more. Successfultactics include e-blasts and emails; outbound phone calls;in-person meetings; marketing campaigns combined with member facingevents like “lunch and learns”; and Web-based training to encouragemember participation.
• Engage internal stakeholders for support and buy-in foran active Member Awareness and Education Campaign As partof the strategic communication planning process, credit unions mustidentify, create and train internal advocates who understand thepurpose and importance of the campaign. Internal stakeholdersshould range from senior-level employees down to the front line. Asa result, the entire team is knowledgeable and able to engagemembers to emphasize the program's importance and further educationand awareness.
• Promote educational material as a value-addedservice Instead of viewing the educational offerings as aburden, credit unions should capitalize on education as a way topromote confidence and concern for the security of online bankingtransactions rather than an inconvenient feature.

An active Member Awareness and Education program should supportongoing strategic initiatives designed to help your members makethe connection between recognizing and preventing online accountfraud.

Members own a large part of the responsibility for the securityof their online banking transactions. Providing valuableinformation to prevent and detect fraud will enhance and deepen therelationship with your members.

Karen Crumbley ismarketing product manager for Gladiator Technology, a solutionfrom Jack Henry & Associates in Monett, Mo.