I for one don't like how companies use email as a security crutch.

Ownership of an address at a particular point in time doesn't equate to proof of identity. One hacked email account and everything else falls like dominos.

Password resets lead to iterative passwords, which lead to password reuse, which lead to email compromise, which leads to it being pointless to use email as some ersatz second factor.

If we want to move towards a world where phishing attacks and password breaches are obsolete, then we need to press full-throttle to mandating hardware security keys for all accounts.

The practices CafePress had prior to its breach were clearly inadequate, and justifiably actionable. They authenticated users with password-equivalent "security questions", which they (of course) stored in clear text. Storing cleartext password reset secrets contravenes universal industry best practices, and, really, so does the use of "security questions" at all --- though many banks still do.

But requiring 2FA tokens is not a universal practice. Moreover, deployed over a whole userbase, it doesn't really address the concerns that lead to or were revealed by this breach. Managing 2FA for non-technical end users --- that's the kind CafePress serves --- is extraordinarily difficult. People lose tokens, 2FA codes are phishable, account recovery remains the most difficult problem in computer security, and so on.

So yes, it is weird to me to see the FTC suggest that the appropriate solution to a broken authentication system with security question is "make people use 2FA tokens". The universal best practice solution to the specific problem the security tokens solved is "password reset emails that prove custody of a trusted email account". The demand from the FTC exceeds that best practice. That's interesting, and so I called it out.

We don't know each other, so it probably bears saying that I am foursquare supportive of 2FA. I'm supportive of a lot of things the FTC would no doubt love to force companies to do (penetration testing in particular!)

It is not universal practice, but it is industry-standard, so I don't particularly understand why it is surprising that the FTC is recommending that CafePress adhere to industry standards.

> To maintain the integrity of the authentication factors, it is essential that it not be possible to leverage an authentication involving one factor to obtain an authenticator of a different factor. For example, a memorized secret must not be usable to obtain a new list of look-up secrets.

And further:

> Methods that do not prove possession of a specific device, such as voice-over-IP (VOIP) or email, SHALL NOT be used for out-of-band authentication.

(Which is good for some of them, as they're notoriously flaky).

Again, 2FA isn't an account recovery process at all; it's a reason you need account recovery.

To get a general sense of where we're at as an industry with this, look at the process for what happens when you lose an AWS 2FA secret:

https://docs.aws.amazon.com/IAM/latest/UserGuide/id_credenti...

Your reading of the FTC text seems to be that you think the FTC has conflated account recovery with 2FA, but I don't think that's the case. Instead, my read is that they're suggesting that password breaches can be rendered moot points by requiring 2FA for accounts, so that the compromise of a password would not require an account reset in the first place.

But technical language aside: a requirement that CafePress fully adopt 2FA also doesn't make sense, because its users will not fully adopt 2FA. The users that can't 2FA are the interesting case here, and the thing I'm calling out.