Technological advances in the financial services industry have significantly changed the consumer– banker relationship. Once, where consumers could be guaranteed face to face encounters with their bankers, today they are increasingly encouraged to use automatic teller machines (ATMs) and online services for day-to-day banking. The days when reliance was placed on the bank as a trusted institution which owed a duty of care to its customers (and in some circumstances a more onerous fiduciary duty) have largely been replaced with limited liability contracts and faceless institutions.