Q: How are organizations responding?
Experian estimates that less than half of the institutions impacted by this guidance are prepared for the examinations. Many of the fraud tools in the marketplace, particularly those that are used to authenticate individuals were deployed as point-solutions. Few support the need for a feedback loop to identify vulnerabilities, or the ability to employ a risk-based, “layered” approach that the guidance is seeking.
This is the last of our five-part series but we’re happy to answer more questions as we know you need to know how to prepare for the January 2012 deadline.