Federal Financial Institutions Examination Council issued guidance on Internet banking last June. Guidance covers customer authentication, layered security, and other controls that can make online banking safer. Financial institutions should implement layered security programs, says FFIEC’s 2011 Supplement. The only gray area is how examiners will interpret it, says Tom Hinkel, director of compliance with technology solutions to financial institutions. CFOs can start with a few questions: “What is your policy? What will do you expect us to do? What’s not going to the customer flow flow?””]