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:

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