The Agencies are concerned that customer authentication methods and controls implemented in conformance with the Guidance several years ago have become less effective. Hence, the institution and its customers may face significant risk where periodic risk assessments and appropriate control enhancements have not routinely occurred. General Supervisory Expectations The concept of customer authentication, as described in the 2005 Guidance, is broad. It includes more than the initial authentication of the customer when he/she connects to the financial institution at login. Since virtually every authentication technique can be compromised, financial institutions should not rely solely on.
