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All i would say is they should have provided 2fa if they didn’t.
At this point, every company not using 2FA is at fault for data hacks. Most people using the internet have logins to 100’s of sites. Knowing where to do to change all your passwords is nearly impossible for a seasoned internet user.
The Alliance Defending Freedom video tapes a sermon by a preacher specifically violating the rule and send it to the IRS, trying to bait them into applying the rule because they are confident SCOTUS will declare the rule unconstitutional. The IRS never takes the bait. They’d rather have the appearance of a rule than no rule at all. As it is it is mostly self-enforcing on most congregations.