May 6, 2001
FYI - From CNET News - The single biggest cause of network
security breaches is not software bugs and unknown network vulnerabilities
but dumb moves by PC users, according to a survey published by computer
consultant @Stake. http://www.internetbankingaudits.com/article050201.htm
FYI - Basel Committee Report Outlines Risk Management
Principles for Electronic Banking that sets forth fourteen risk management
principles on electronic banking for financial institutions in a report
issued today. Press release http://www.occ.treas.gov/ftp/release/2001-42.txt
E-banking paper http://www.occ.treas.gov/idtheft.pdf
INTERNET COMPLIANCE - This is the last of two comments regarding
Electronic Fund Transfer Act (Regulation E.)
The Federal Reserve Board Official Staff Commentary (OSC) also
clarifies that terminal receipts are unnecessary for transfers initiated
on-line. Specifically, OSC regulations provides that, because the term
"electronic terminal" excludes a telephone operated by a
consumer, financial institutions need not provide a terminal receipt when
a consumer initiates a transfer by a means analogous in function to a
telephone, such as by a personal computer or a facsimile machine.
Additionally, the regulations clarifies that a written authorization
for preauthorized transfers from a consumer's account includes an
electronic authorization that is not signed, but similarly authenticated
by the consumer, such as through the use of a security code. According to
the OSC, an example of a consumer's authorization that is not in the form
of a signed writing but is, instead, "similarly authenticated"
is a consumer's authorization via a home banking system. To satisfy the
regulatory requirements, the institution must have some means to identify
the consumer (such as a security code) and make a paper copy of the
authorization available (automatically or upon request). The text of the
electronic authorization must be displayed on a computer screen or other
visual display that enables the consumer to read the communication from
the institution.
Only the consumer may authorize the transfer and not, for example, a
third-party merchant on behalf of the consumer.
Pursuant to the regulations, timing in reporting an unauthorized
transaction, loss, or theft of an access device determines a consumer's
liability. A financial institution may receive correspondence through an
electronic medium concerning an unauthorized transaction, loss, or theft
of an access device. Therefore, the institution should ensure that
controls are in place to review these notifications and also to ensure
that an investigation is initiated as required.
INTERNET SECURITY - We continue the series from the FDIC "Security
Risks Associated with the Internet." While this Financial Institution
Letter was published in December 1997, the issues still are relevant.
Data Integrity
Potentially, the open architecture of the Internet can allow those with
specific knowledge and tools to alter or modify data during a
transmission. Data integrity could also be compromised within the data
storage system itself, both intentionally and unintentionally, if proper
access controls are not maintained. Steps must be taken to ensure that all
data is maintained in its original or intended form.
Authentication
Essential in electronic commerce is the need to verify that a
particular communication, transaction, or access request is legitimate. To
illustrate, computer systems on the Internet are identified by an Internet
protocol (IP) address, much like a telephone is identified by a phone
number. Through a variety of techniques, generally known as "IP
spoofing" (i.e., impersonating), one computer can actually claim to
be another. Likewise, user identity can be misrepresented as well. In
fact, it is relatively simple to send e-mail which appears to have come
from someone else, or even send it anonymously. Therefore, authentication
controls are necessary to establish the identities of all parties to a
communication.
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