We also understand the depth and complexity of the issues that banks face today, from capital to credit risk to compliance issues, and we acknowledge that in some cases these issues are particularly challenging for smaller financial institutions. At the Federal Reserve, we are doing everything we can to keep the playing field level as our policies and regulatory practices evolve with the industry.
Systems should be developed in such a way that a customer can use his ATM card and his own ATM PIN (Personal Identification Number) for customer authentication in a Web transaction, which is normally not done in a Web-based transaction or in any other delivery channel.