Joseph Burton, an attorney who focuses on emerging financial fraud trends, says most banks and credit unions are spending far too much time on authentication. Burton says many institutions have invested far less in other security layers, such as fraud detection and out-of-band verification, also noted in the FFIEC guidance. He says layered security is the key for both commercial and for retail-level transactions. Burton is a former Assistant U.S. Attorney and Chief of the Silicon Valley Office for the Northern District of California.”]
Source: https://www.cuinfosecurity.com/layered-security-key-to-compliance-a-4701