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Cross-Media Electronic Reporting Rule

User Identification, Verification, and Authentication: Challenge Question Second-Factor Approach

EPA has determined that to meet the CROMERR requirement, a system using PIN/password must be accompanied by some other identifier that, together with the PIN/password, will be sufficient to prove that the e-signature has not been compromised. One approach is to use the PIN/password in conjunction with a ‘second factor’ to create an e-signature. This document outlines the use of challenge questions as one approach to meeting this CROMERR requirement.

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