The "stepped" liability provisions in 205.6 apply when an access device is used. An access device can include a token, a code, etc., in addition to a card. So if a financial institution issues a code for logging in to its internet banking site, that code could be considered an access device.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8