Re:Look at Swiss or German Banks (Score 1)

Swiss and German Banks have been doing this for years, in varying degrees. Some like Credit Suisse gave out SecurIDs. Others, like the Swiss Postbank and Sparkasse, sent out long sheets of random numbers. The websites required a pin, account number and the next unused number on your list.

It worked very well, and it wasn't rocket science.

And, honestly, it is not as if most US institutions are actually going to comply with this by the deadline. There will be some many inane waivers available that push the deadline back in significant ways, b/c the government is too scared to hold anyone accountable or provide leadership.