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This model means that trust must verifiable and reciprocal -- meaning the Bank can authenticate the user (BTU) and the user can authenticate the Bank (UTB). Much of the FFIEC guidelines (and, not surprisingly, the industry's solutions) solely focus on two factor authentication solutions. However, unless the user authenticates the bank as a legitimate site, 2 factor authentication will provide no security to the customer.
4 key challenges financial institutions must address to comply with Best Practices Mutual Authentication solution

Challenge 1. FI's need to authenticate Users
Challenge 2. Provide consumers with means to establish site identity even if a Man-in-the-Middle attack has been launched
Challenge 3. FI's need to provide ID assurance for email communications to inter and intra-office
Challenge 4. FI's must provide a secure transaction environment that prevents malware from making internet connections mid-session
4 key challenges financial institutions must address to comply with a Best Practices Mutual Authentication solution.
Only with Comodo's PKI Online Trust-compliant Solutions can a Best Practices Model be deployed easily and cost effectively.
1) Comodo Content Verification Certificates
2) Comodo Digital Client Certificates
3) Comodo's Lock Down /SEE technology
4) eMail Certificates
Learn more about Comodo's FFIEC compliant, integrated Best Practices Two Factor Authentication Solution.