Monday, July 03, 2017 4:00:29 PM
your really confused
the 2001 guidance MFA was A standard
the 2006 guidance you keep referring to was just UPDATED 2001 guidance so that institutions would risk assess their customers/ online transactions to see which transactions/customers Single factor would be inadequate for, customer awareness and aditional enhanced security as explained in the first paragraph of the 2006 guidance you just linked.
Here is the part you left out.
when risk assessments indicate the use of single-factor authentication is inadequate, financial institutions should implement multifactor authentication, layered security, or other controls reasonably calculated to mitigate those risks.
Now I think this is where you are confused, if you have access to customer information, or your moving money you need MFA, layered security or other controls.
AS I have stated many times. IN 2001 MFA was here and A industry standard, there are many forms of MFA and oob/mfa Not the only form acceptable, but A standard.
The 2012 Guidance further expanded the 2001 and 2006 to cover OOB/MFA for High risk transactions. and as show before
So if you log into your bank account online and can see customer info (YOU CAN, IT's your bank account, statements, images, etc) or can move money to "other parties". Single factor authentication HAS BEEN INADEQUATE since 2001, and MFA, layered security, or other access controls are needed, since 2012 oob/mfa!
Here are all 3 FFIEC standards
2001
2006
2012 regs
As stated and proven, mfa has been a industry standard since 2001,
OOB/MFA has been industry standard since 2012
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