Giving the account number on the card is the access device.

Not dissimilar, I borrow David's cell to make a call. While on the "private call" I explore his phone and make a purchase or two. It's similar although there was no intent to share that info or allow a purchase. That is where I think the similarity ends. Inputting the info on one device is not lending my device to someone else. My key point is to reiterate what I recall has already been said, Reg E is not keeping up. If I were facing a CFPB attorney charged with enforcing Reg E I believe they'd come back in each case to "did the consumer do it, authorize it or benefit from it?" And if I had to ask those examiners, I believe the claim would be paid. I'm not saying it's right. But perhaps a call for an opinion is in order.