The New York Department of Financial Services (“NYDFS”) has brought action in Federal court against Citibank, N.A., alleging that the bank systemically failed to protect accountholders from rampant online scam activity, leading to individual losses amounting to tens, or hundreds of thousands. In taking this step, NYDFS seeks formal recognition of depository institutions’ liability under the Electronic Funds Transfer Act (EFTA) to safeguard depositors from...