Bank records and checks do constitute trade secrets, which are defined as any formula, pattern, device, or compilation of information which is used in one's business, and which gives one an opportunity to obtain an advantage over competitors who do not know or use it.
Landmark Ventures, Inc. v. Kreisberg & Maitland, LLP, NY Slip Op 00248 (1st Dep't January 14, 2020
Here is the decision.