Gone are the days when paper checks were used as the dominant means for making payments from accounts. The number of checks written has so rapidly declined that the Federal Reserve Bank now operates only one clearing location for paper checks, in Cleveland, down from 45 locations. Press Release, Fed. Reserve System, Fin. Servs. Policy Comm., Federal Reserve Banks Complete Check Processing Infrastructure Changes (Mar. 2, 2010). The majority of Americans, consumers and businesses alike, prefer the ease and convenience of electronic banking. In fact, as of 2013, 51 percent of United States adults and 61 percent of Internet users bank online. Susannah Fox, 51% of U.S. Adults Bank Online(Pew Research Ctr. Aug. 7, 2013). This reflects the modern reality that banking is increasingly becoming an electronic endeavor.
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