In June 2011, the FFIEC issued its Supplement to Authentication in an Internet Banking Environment. This was originally met with a great deal of questioning and requests for clarity. The dust has now settled, and financial institutions are expected to understand the guidance objectives and have initiatives in place to address accordingly.
I’ve been working with credit unions to meet the goals required of this new guidance for more than two years, and there still remain many institutions struggling with the FFIEC’s member awareness and education demands. There appears to be a gap between providing educational materials to members (business and consumer) and members acknowledging their receipt and understanding of the materials.
Here are some of the reasons why I believe members may be ignoring educational materials:
- The educational material is not compelling Regardless of the distribution method, the material simply fails to capture members’ attention. Credit unions may use multiple distribution channels such as website posts, brochures, statement stuffers, but with the inundation of materials that members receive from their financial institutions and hundreds of other sources, educational materials are largely overlooked.
- A strategic communication plan and messaging is missing Many credit unions fail to create and follow a strategic roadmap for ongoing Member Awareness and Education Program initiatives. As a result, messaging begins to lack specific focus and does not create compelling reasons why members should be attentive to the communications regarding the need for additional or enhanced technology controls to prevent/detect fraud.
- The Member Awareness and Education Program is stuck on that “backburner” The Member Awareness and Education Program component of the FFIEC guidance is not a priority and other projects have taken precedence, leaving enhancements in the conceptual phase. This may become an issue due to expectations outlined in the guidance. For instance, the FFIEC guidance advises that there are, “certain specific minimum elements that should be part of an institution’s member awareness and education program.” If the credit union’s educational program does not include these items, then it is opening it up to examiner scrutiny. However, examiner scrutiny should not be the primary reason for enhancing the educational campaign, there is an enormous opportunity to mitigate fraud.
- Executives are concerned that intentional efforts to encourage education may alienate commercial members Typically, credit unions do not want to impose on their members by making education mandatory. As a result, many commercial members are falsely under the impression that their accounts are protected and insured against fraud. In reality, helping a business to protect against fraud is not an imposition at all, but a service. Focusing on this message will help commercial members realize the value and necessity of staying informed and helping to do their part.
Next Page: A Few Key Tactics
- Leveraging unique delivery channels for communicating to the higher-risk commercial member This is more than a compliance initiative; it is also an opportunity to build relationships. Credit unions are using specific campaigns designed to create interest and a desire to learn more. Successful tactics include e-blasts and emails; outbound phone calls; in-person meetings; marketing campaigns combined with member facing events like “lunch and learns”; and Web-based training to encourage member participation.
- Engage internal stakeholders for support and buy-in for an active Member Awareness and Education Campaign As part of the strategic communication planning process, credit unions must identify, create and train internal advocates who understand the purpose and importance of the campaign. Internal stakeholders should range from senior-level employees down to the front line. As a result, the entire team is knowledgeable and able to engage members to emphasize the program’s importance and further education and awareness.
- Promote educational material as a value-added service Instead of viewing the educational offerings as a burden, credit unions should capitalize on education as a way to promote confidence and concern for the security of online banking transactions rather than an inconvenient feature.
An active Member Awareness and Education program should support ongoing strategic initiatives designed to help your members make the connection between recognizing and preventing online account fraud.
Members own a large part of the responsibility for the security of their online banking transactions. Providing valuable information to prevent and detect fraud will enhance and deepen the relationship with your members.