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The United States banking industry was directed by its regulatory agencies to provide authentication stronger than single factor for "high risk" transactions, as a defense against phishing, by year-end 2006. Financial institutions had a wide array of options available to them to meet this requirement, and there was considerable latitude in how to interpret the regulatory guidance. This paper presents the results of a multiple case study, reviewing regulation, regulatory intent, and financialdblp:conf/amcis/Witman07 fatcat:42jwdpz3kvduhjj7nkwmqiwpca