I'm not a lawyer, but if I'm reading the actual regulation [0] correctly, it would only apply in the case of prompt injection or other malicious activity. 1005.2.m defines "Unauthorized electronic fund transfer" as follows:
> an electronic fund transfer from a consumer's account initiated by a person other than the consumer without actual authority to initiate the transfer and from which the consumer receives no benefit
OpenClaw is not legally a person, it's a program. A program which is being operated by the consumer or a person authorized by said consumer to act on their behalf. Further, any access to funds it has would have to be granted by the consumer (or a human agent thereof). Therefore, baring something like a prompt injection attack, it doesn't seem that transfers initiated by OpenClaw would be considered unauthorized.
[0]: https://www.consumerfinance.gov/rules-policy/regulations/100...
Good point. Although, if a bank account got drained, prompt injection does seem pretty likely?
Would you say you might be able to... claw.... back that money?
"Take this card, son, you can do whatever you want with it." Goes on to withdraw 100000$. Unauthorized????