Title: Message
Like running to a bank/post office and getting a certificate?
Certs are just a password verification tool, where user password verification occurs locally intead of at the server.  This is NOT two-factor byt any definition, just a password verificaiton displacement tool.
 
At a very quick look at the documentation, Australian banks have had similar guidelines for some months. 
The key requirement seems to be "do a risk assessment, and act based on the outcome".  Everything else is optional, based on the risk assessment, however that is performed, and whatever that internal document recommends. 
On this model, its easy to justify not doing anything, since the fraud dollar losses don't seems to be even a few percent of the costs to implement and support two factor hardware devices based on the anecdotal evidence and reviews I''ve seen.
 
Lyal
 
 
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Casey DeBerry
Sent: Thursday, 13 October 2005 7:30 AM
To: full-disclosure@lists.grok.org.uk
Subject: [Full-disclosure] NEW USA FFIES Guidance

For those that fall under US FFIEC governance, what are you doing to satisfy these requirements?  I'd like to think I have more options than running to the store to pick up my RSA keyfobs...  What about PKI?  Are there other options for web based apps?
 
http://www.fdic.gov/news/news/financial/2005/fil10305.html
 
C. DeBerry
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