The case Patco Construction Co. Inc. v. People's United Bank d/b/a Ocean Bank, D. Maine, No. 2:09-CV-00503-DBH, 1/19/10) is one of several recent cases alleging breaches of online security in financial transactions that may provide some guidelines as to what constitutes "reasonable care" in online financial transactions. The case alleges that use of several "challenge questions" added no practical safety beyond a password, and that additional mechanisms such as authentication tokens are required to meet the commercially reasonable standard. (Commercial banks are required to take "commercially reasonable" steps to protect customers against fraud.)
This case could be one more step towards a requirement of multi-factor authentication in financial transactions.