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1 dd4ff commented Permalink

I could argue many of the points you raise.

 
But, let's instead take a different view on this and ignore all of the security stuff (but my personal e-mail has more security then this bank required for >$100,000 transfers to fishy accounts).
 
In my opinion, the bank should settle this matter immediately. If this case is decided in their favor, what business would accept the risk of working with small and medium sized banks in any significant capacity when they realize that these banks will be held to a much lower security standard when it matters?
 
From the recommended decision: "It is reasonable to require large money center banks to make available state-of-the-art security procedures. On the other hand, the same requirement may not be reasonable for a small country bank."
 
What more effective way is there to drive your customers away to large banks? What was it $600k? Call it marketing money. Would this bank, or any small or mid-sized bank, publicly say, "We'll take less care of your money then our competition." if I offered them $600k to say it?
 
They may well win. But in the end they will lose if they do.

2 dd4ff commented Permalink

There's an FFIEC update related to this topic out as of yesterday here: http://www.ffiec.gov/pdf/Auth-ITS-Final%206-22-11%20%28FFIEC%20Formated%29.pdf