Consumer versus Commercial Transfers. Shawmut Worcester County Bank, a Massachusetts bank, ...

Consumer versus Commercial Transfers. Shawmut Worcester County Bank, a Massachusetts bank, transferred 10,000 to First American Bank & Trust of Palm Beach, Florida, through Fedwire. Shawmut's payment order stated that the beneficiary of the transfer was Fernando Degan and that First American should credit account number 100 205 001 633. It turned out that the First American account under that number was held jointly by Degan and Joseph Merle. When Shawmut discovered its error 106 days after the mistaken transfer, it credited the account of its customer who had requested the transfer with the 10,000 and then asked First American to reverse the transfer. First American asked Merle, its customer, if he would authorize the reversal. Merle refused. Accordingly, First American told Shawmut it would not reverse the transfer. Shawmut then sued First American to recover the 10,000, alleging, among other claims, that the transaction fell under the EFTA, which prescribes specific requirements that must be followed in the event of error in an electronic fund transfer. Is Shawmut a consumer within the meaning of the EFTA? How should the court rule?