"With the majority of financial institutions in compliance after the frenzied rush to meet the authentication requirements of the 2005 FFIEC Guidance, a number of financial institutions have relaxed into a satisfied mode. Compliance is not security, however, and complacency increases risk. Weaknesses have already been proven for widely adopted methods such as mutual authentication and device recognition."
Among the most extensive comments received are those of Bank of America filed by executives Lance Weaver and Susan Faulkner in a 50+ page filing. They begin: "The proposal would substantially reinvent the business of credit card lending and deposit taking. ... This proposal will have a broad impact on the economy both at the retail level and in highly complex securitization markets, slowing growth and limiting access to financing."
We have received news of the following recent management changes: