Many industry experts have voiced disappointment regarding the FFIEC's recently revised guidance for the security of electronic banking activities. Before we become too judgmental, we must applaud the council's efforts to open the conversation about the increase and drastic change in cyber-security threats since its first guidance, Authentication in an Internet Banking Environment, was issued back in 2005.

As a whole, the financial services industry needs to strategically address online fraud and proper mitigation techniques, rather than continuing to overlook the elephant in the room. Institutional reputation is at stake as well as the trust of your members.

The FFIEC should be congratulated for publishing its guidance quickly, acknowledging that fraud has outpaced its original regulations. And, despite the guidance leaked months ago that suggested extreme security measures such as having a PC dedicated solely to online banking, the actual implications are extremely obtainable. Credit unions, no matter their size, should have no trouble meeting the January 2012 deadline.