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In Fraudulent Wire Transfer Case, UCC Rules Displace Simple Negligence Claim

LexisNexis (May 3, 2018, 10:41 AM EDT) -- In our prior story, we reported on a 2017 Massachusetts case in which the check-fraud rules of UCC Article 4 displaced a common-law negligence claim brought by the plaintiff.  Even more recently, in a case decided in 2018, a Delaware court dismissed a "simple negligence claim" of a customer against its bank arising out of unauthorized wire transfers originated by the customer's trusted employee; the court ruled that the loss-allocation rules of UCC Article 4A displaced the common-law negligence claim brought by the customer. These cases...
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