On July 3, 2012, in Patco Construction Co. v. People’s United Bank, the First Circuit held that security procedures used to verify electronic funds transfers initiated through online banking were commercially unreasonable. In reaching its decision, the court laid a strong foundation for analyzing commercial reasonableness in future cases. This Comment argues that future courts should build on this analysis by considering recent merger activity when determining the standard against which commercial reasonableness should be measured.
Melissa Waite, In Search of the Right Balance: Patco Lays the Foundation for Analyzing the Commercial Reasonableness of Security Procedures under UCC Article 4A, 54 B.C.L. Rev. E. Supp. 217 (2013), http://lawdigitalcommons.bc.edu/bclr/vol54/iss6/17