In May 2009, an unknown hacker gained access to PATCO Constructions online banking account. A federal court of appeals reversed a lower-court ruling, saying bank’s security system was commercially unreasonable Recent court rulings indicate that the manner in which the technologies are implemented and operated are critical factors in determining commercial reasonableness. With regulators and courts stepping in to protect SMBs, the days of banks using UCC 4A to deflect fraud liability to the customer are over.”]