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Wells Fargo's new Online Access Agreement will take effect on November 24, 2026, adding a new Article 15: once a user authorizes a third-party AI agent to use online banking credentials to access the account, instructions and transactions initiated by the agent are deemed to be the user's own actions, and the risk is borne by the user; the bank does not undertake to monitor them and reserves the right to restrict access. A 36Kr AI report notes that JPMorgan Chase, Bank of America, Citibank, and Charles Schwab have chosen to restrict or block third-party AI agents from logging in, while Wells Fargo shifts liability to users upfront through contract, basing this on the exception clause in Regulation E for unauthorized transactions; currently no court or regulator has issued a clear ruling. The report also compares this with the "Self-Discipline Convention on the Application of Agent Payments" issued by the Payment & Clearing Association of China in August 2026, which establishes that licensed institutions bear primary responsibility and requires exploration of a KYA mechanism.
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Nov 5
36Kr · AI
Wells Fargo's New Agreement Assigns Responsibility for AI Agent Operations to Users
Wells Fargo's new version of its Online Access Agreement will take effect on November 24, 2026. The newly added Section 15 provides that after a user authorizes a third-party AI agent to use online banking credentials to access an account, instructions and transactions initiated by the agent are deemed to be the user's own actions, with the risk borne by the user; the bank does not undertake to monitor them and reserves the right to restrict access. The article notes that JPMorgan Chase, Bank of America, Citibank, and Charles Schwab have chosen to restrict or block third-party AI agent logins, whereas Wells Fargo uses contractual means to shift responsibility to users upfront; its basis is the exception clause in Regulation E for unauthorized transactions, and no court or regulator has yet issued a clear ruling. The article also compares China Payment & Clearing Association's Self-Disciplinary Convention on the Application of Agent Payments released in August 2026, which establishes that licensed institutions bear primary responsibility and requires exploration of a KYA mechanism.