Hm, sure? My comdirect account uses a 6 digits pin. Never tried to use more than that. But 6 were still horrible enough when looking at the fact, that SEPA transfers of up to 30 Euros don't require entry of a TAN. A feature, which can't be disabled. Hate comdirect for that move.
EDIT: feature, not option. :)
And, yes, the forced TAN-less transfers is why I am closing down my accounts. That is, they forcing thid disfeature on me, and their impertinent reaction when I rejected their bullshit justification (essentially they calling me rude and therefore refusing any further conversation because I pointed out that "many customers like this feature" is not a reason to force it and the risk that comes with it on customers who don't like it).