See, this stuff isn't black and white: I'd rather see these decisions made based on what a company could have easily done. AT&T getting their customer service techs some basic anti-social-engineering training, *or* discouraging 2FA, is easy and would prevent a lot of harm.
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I think the standard of reasonable care doesn't mean they need such warnings to be complete at all, far from it: it's perfectly reasonable to focus only on common hazards. 2FA hacking is very common.
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Not a fan of AT&T, however, they are not a bank and therefore cannot expected to provide fin-tech level security on accounts. Delegation of security to a less secure system or company is failure by design.
End of conversation
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