Has there been a change in US banking regulations recently?

2010-08-13 Thread Peter Gutmann
As part of a thread on another list, I noticed that Bank of America, who until
recently didn't bother protecting the page where users are expected to enter
their credentials with anything more substantial than a GIF of a padlock, now
finally use HTTPS on their home page, and redirect HTTP to HTTPS (this only
took them, what, about ten years to get right?  Or is it fifteen?  When did
BofA first get a web presence?).  Wachovia now do it too.  And Citibank at
least redirect you to an HTTPS page.  And so does US Bank, after asking for
your ID.

What on earth happened?  Was there a change in banking regulations in the last
few months?

Peter.

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Re: Has there been a change in US banking regulations recently?

2010-08-13 Thread Perry E. Metzger
On Fri, 13 Aug 2010 23:59:18 +1200 Peter Gutmann
 wrote:
> As part of a thread on another list, I noticed that Bank of
> America, who until recently didn't bother protecting the page where
> users are expected to enter their credentials with anything more
> substantial than a GIF of a padlock, now finally use HTTPS on their
> home page, and redirect HTTP to HTTPS (this only took them, what,
> about ten years to get right?  Or is it fifteen?  When did BofA
> first get a web presence?).  Wachovia now do it too.  And Citibank
> at least redirect you to an HTTPS page.  And so does US Bank, after
> asking for your ID.
> 
> What on earth happened?  Was there a change in banking regulations
> in the last few months?

I don't know, but Chase, which years ago sent me a letter explaining
exactly how crazy I was for complaining that their front page was
sent in the clear, has also begun redirecting people to https. I'm
unaware of a regulatory shift on this, but perhaps people have
finally learned that doing otherwise is a bad idea.

Perry
-- 
Perry E. Metzgerpe...@piermont.com

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RE: Has there been a change in US banking regulations recently?

2010-08-13 Thread eric.lengvenis
On Fri, 13 Aug 2010 23:59:18 +1200 Peter Gutmann  
wrote:
> As part of a thread on another list, I noticed that Bank of America, 
> who until recently didn't bother protecting the page where users are 
> expected to enter their credentials with anything more substantial 
> than a GIF of a padlock, now finally use HTTPS on their home page, and 
> redirect HTTP to HTTPS (this only took them, what, about ten years to 
> get right?  Or is it fifteen?  When did BofA first get a web 
> presence?).  Wachovia now do it too.  And Citibank at least redirect 
> you to an HTTPS page.  And so does US Bank, after asking for your ID.
> 
> What on earth happened?  Was there a change in banking regulations in 
> the last few months?

I'm usually pretty up-to-date on these regulations and I'm not aware of any 
recent changes. As for Wachovia's changes, you'll notice that it now says "A 
Wells Fargo Company" in smaller print beneath the Wachovia logo. That's the 
reason for their switch; our name on their (our?) site. Unfortunately, it 
appears that not all is working right. If you go to http://wachovia.com it 
redirects to https://www.wachovia.com just fine, but if you type in 
https://wachovia.com it does not redirect you and your browser will throw a 
domain name mismatch error because the certificate is for www.wachovia.com 
(Confirmed on IE8, Firefox 3.5, and Chrome 5). The browser treat these as near 
apocalyptic errors with huge warnings. Firefox especially. I've notified the 
appropriate people. 

Eric Lengvenis
Information Security Architect
Enterprise Information Security Architecture (EISA)

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Re: Has there been a change in US banking regulations recently?

2010-08-13 Thread Jeff Simmons
On Friday 13 August 2010 04:59, Peter Gutmann wrote:
> As part of a thread on another list, I noticed that Bank of America, who
> until recently didn't bother protecting the page where users are expected
> to enter their credentials with anything more substantial than a GIF of a
> padlock, now finally use HTTPS on their home page, and redirect HTTP to
> HTTPS (this only took them, what, about ten years to get right?  Or is it
> fifteen?  When did BofA first get a web presence?).  Wachovia now do it
> too.  And Citibank at least redirect you to an HTTPS page.  And so does US
> Bank, after asking for your ID.
>
> What on earth happened?  Was there a change in banking regulations in the
> last few months?
>
> Peter.

It wouldn't surprise me if there's been some blowback from the adoption of 
PCI-DSS (Payment Card Industry Data Security Standards). As someone who has 
had to help several small to medium size businesses comply with these 
'voluntary' standards, the irony of the fact that the big banks that require 
them often aren't in compliance themselves hasn't escaped my notice.

-- 
Jeff Simmons   jsimm...@goblin.punk.net
Simmons Consulting - Network Engineering, Administration, Security
"You guys, I don't hear any noise.  Are you sure you're doing it right?"
--  My Life With The Thrill Kill Kult

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Re: Has there been a change in US banking regulations recently?

2010-08-13 Thread John Levine
>What on earth happened?  Was there a change in banking regulations in
>the last few months?

No, but we know that banks move in herds, and they mostly talk to each
other, not anyone with outside expertise.

More likely someone noticed that computers are a lot faster than they
were a decade ago, you can do all the crypto you want and your 8 core
3 GNz servers are still I/O bound, so the traditional folklore that
SSL is so slow you use it only where absolutely mandatory no longer
applies and you might as well use SSL on everything.  Then he went to
a meeting and told all his friends.

I've been noticing something similar at abuse.net, a service I run
where people can publish their domains' abuse contacts.  The folklore
in small credit unions is that you're supposed to hide your domain's
registration details using a proxy service, I think due to a
misreading of an old letter from the NCUA.  Earlier this year someone
at a meeting must have told them that it would be a good idea to
register with abuse.net, so I've been getting a stream of attempted
registrations from small credit unions with proxy registration, which
I reject.  About half of them get the hint, turn off the proxy, and
try again, the other half give up.

R's,
John

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Re: Has there been a change in US banking regulations recently?

2010-08-13 Thread Jon Callas
> What on earth happened?  Was there a change in banking regulations in the last
> few months?

Possibly it's related to PCI DSS and other work that BITS has been doing. Also, 
if one major player cleans up their act and sings about how cool they are, then 
that can cause the ice to break.

Another possibility is that a number of people in financials have been able to 
get security funding despite the banking disasters because the risk managers 
know that the last thing they need is a security brouhaha while they are 
partially owned by government and thus voters.

I bet on synergies between both.

If I were a CSO at a bank, I might encourage a colleague to make a presentation 
about how their security cleanups position them to get an advantage at getting 
out from under the thumb of the feds over their competitors. Then I would make 
sure the finance guys got a leaked copy.

Jon

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RE: Has there been a change in US banking regulations recently?

2010-08-13 Thread eric.lengvenis
>Jon Callas wrote:
>
> Possibly it's related to PCI DSS and other work that BITS has been doing. 
>  
>
> Another possibility is... the risk managers
> know that the last thing they need is a security brouhaha while they are
> partially owned by government and thus voters.
> 
> I bet on synergies between both.
> 

I agree. I think it is just the 100th monkey effect.

Eric Lengvenis
InfoSec Arch.

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RE: Has there been a change in US banking regulations recently?

2010-08-13 Thread eric.lengvenis
> Jeff Simmons wrote:

> It wouldn't surprise me if there's been some blowback from the adoption of
> PCI-DSS (Payment Card Industry Data Security Standards). As someone who
> has
> had to help several small to medium size businesses comply with these
> 'voluntary' standards, the irony of the fact that the big banks that require
> them often aren't in compliance themselves hasn't escaped my notice.

I'd like to clarify a bit. PCI-DSS wasn't developed by the big banks. It isn't 
usually enforced by big banks except insofar as they are liable for PCI-DSS 
compliance when outsourcing to or partnering with other companies. So they may 
be forcing it on the SMBs you've worked with because they're liable in some way.

PCI-DSS was the brainchild of Visa. I'm a member of X9F (X9F6 is the payment 
card security standards committee) and we wrote an open letter back in 2005 to 
Visa and Mastercard asking them not to set new, separate standards for the 
financial sector but to work from within X9F. They ignored us. Even though you 
clearly indicate that they aren't truly voluntary via your use of quotes, when 
the PCI group (VISA et al.) can unilaterally level huge fines and/or penalties 
for non-compliance they really are compulsory.

Luckily, PCI-DSS compliance != security. Or is that unluckily because of how 
much money is wasted complying that could be better spent securing.

Eric Lengvenis
InfoSec Arch

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Re: Has there been a change in US banking regulations recently?

2010-08-13 Thread Anne & Lynn Wheeler

On 08/13/2010 02:12 PM, Jon Callas wrote:

What on earth happened?  Was there a change in banking regulations in the last
few months?


Possibly it's related to PCI DSS and other work that BITS has been doing. Also, 
if one major player cleans up their act and sings about how cool they are, then 
that can cause the ice to break.

Another possibility is that a number of people in financials have been able to 
get security funding despite the banking disasters because the risk managers 
know that the last thing they need is a security brouhaha while they are 
partially owned by government and thus voters.

I bet on synergies between both.

If I were a CSO at a bank, I might encourage a colleague to make a presentation 
about how their security cleanups position them to get an advantage at getting 
out from under the thumb of the feds over their competitors. Then I would make 
sure the finance guys got a leaked copy.

Jon


the original requirement for SSL deployment was that it was on from the 
original URL entered by the user. The drop-back to using SSL for only small 
subset ... was based on computational load caused by SSL cryptography  in 
the online merchant scenario, it cut thruput by 90-95%; alternative to handle 
the online merchant scenario for total user interaction would have required 
increasing the number of servers by factor of 10-20.

One possibility is that the institution has increased the server capacity ... 
and/or added specific hardware to handle the cryptographic load.

A lot of banking websites are not RYO (roll-your-own), internally developed ... 
but stuff they by from vendor and/or have the website wholly outsourced.

Also some number of large institutions have their websites outsourced to 
vendors with large replicated sites at multiple places in the world ... and 
users interaction gets redirected to the closest server farm. I've noticed this 
periodically when the server farm domain name and/or server farm SSL 
certificate bleeds thru ... because of some sort of configuration and/or 
operational problems (rather than seeing the institution SSL certificate that I 
thot I was talking to).

Another possibility is that the vendor product that they may be using for the 
website and/or the outsourcer that is being used ... has somehow been upgraded 
(software &/or hardware).

--
virtualization experience starting Jan1968, online at home since Mar1970

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