On Nov 22, 2006, at 3:55 AM, Christian Stimming wrote:

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>
> Hi all,
>
> on gnucash-devel someone posted a link to some disturbing news:
>
>> Btw, I heard that US banks are soon going to drop OFX
>> because of new federal regulations that require
>> stronger authentication.
>>
>> http://www.mcse.ms/message2309357.html
>
> Quote from there:
>
>> Case in point: HSBC just notified customers that Direct Connect will
>> not be supported after December 10. When I called customer service  
>> for Online
>> Banking they said they have no plans to reinstate the feature, it is
>> suspended indefinitely. MBNA also recently suspended Direct Connect.

MBNA is now part of Bank of America. I think their information  
systems switchover happened this fall. I don't think BofA turned off  
DirectConnect. I think they just turned off all the old MBNA servers.

>
> *cough*. What are these banks thinking? Are these banks thinking at  
> all?

These banks are thinking that federal regulators may be knocking at  
their door soon. (As an aside, I claim that US banks have a long  
history of not caring about their customers' convenience. The bigger  
the bank, the less they care. Citibank has repeatedly proven that  
they really don't want my business. Astonishing.)

In October 2005 the FFIEC issued "Guidance" on security in  
authentication for  online banking:

http://www.ffiec.gov/pdf/authentication_guidance.pdf

In August 2006, they issued a FAQ on the "Guidance":

http://www.ffiec.gov/pdf/authentication_faq.pdf

The deadline for compliance appears to be 31 December 2006.

Basically, what the board of governors said was "Hey! Banks! You  
idiots are making it easy for criminals to engage in identity theft  
and bank fraud. Stop it!"

While the FAQ specifically states that the board is NOT requiring  
multifactor authentication, they also state that single factor  
authentication alone is clearly inadequate for high-risk situations.  
High risk situations are: access to nonpublic customer information  
(can you say "account balance" and "transaction list"? I knew you  
could.) and transfer of funds to outside parties (bill pay, anyone?).

Interestingly, the FAQ also specifically states that a second  
password entered at a different time during the interaction does not  
count as more than single-factor. What HSBC has done is institute a  
second password that must be entered by clicking with a mouse on an  
on-screen keypad. The only way this strategy will pass the board's  
scrutiny is if HSBC's risk analysis identified keystroke loggers as  
the most important near-term security risk. In any event, HSBC's  
solution is also clearly incompatible with ofxdirectconnect as  
implemented by Intuit.

I also find it curious that they haven't instituted the second  
password for general account access (their online docs mention the  
second security key only for bill pay, not general account access.  
But the general access demo is down today, so who knows...). Clearly,  
almost any online transaction that does anything useful for customers  
will be classified as high-risk by the regulators.

>
> I just *hope* the German banks still know about their advantages with
> HBCI and won't drop this in the near future...

I think the German banks have been way ahead of US banks with respect  
to security. At least several of them have secondary authentication  
tokens that are partially or fully accessible from open source software.

I have been hoping for some event to motivate the banks to pursue  
better security, but it looks like the banks are responding by  
telling customers that "the feds changed the regulations, and that  
service is no longer available" (or..., "Yippee, we get to blame the  
regulators for saving us money on customer systems...").

My biggest fear is that Intuit will use the new guidance as leverage  
to create a closed two-factor authentication system that they'll bolt  
onto the front end of the existing ofxdc process, locking everybody  
else out without changing the data stream at all. And for this favor,  
they'll only double the banks' current bills from Intuit. So far, I  
haven't found any documentation at Intuit's site that they have  
changed anything with respect to authentication in Quicken 2007. I  
see babbling about multilayer security (another 'good thing'  
mentioned in the FFIEC guidance), but that's all protecting the  
transport, not the authentication. If Intuit/Quicken isn't ready  
(capable) of complying by the beginning of 2007, an extension for the  
banks might happen, even when the FAQ (issued a couple months ago)  
says the board of governors has no intention of offering a general  
extension.

Maybe I should be optimistic instead of cynical... Ha.

>
> Christian
>
Dave
--
David Reiser
[EMAIL PROTECTED]


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