LexisNexis (July 6, 2017, 2:46 PM EDT) -- In check and wire fraud cases, a bank's first line of defense is that the plaintiff's claim is barred by (1) the UCC three-year statute of limitations or (2) the one-year statute of repose. In a recent decision from North Dakota, the court has ruled, in a check fraud case, that the three-year UCC statute of limitations can't be extended by the "discovery rule." Although this ruling is consistent with the weight of authority around the country, it is notable that North Dakota has now fallen in line even though, historically, it strictly adheres to the discovery rule in tort and other litigation. A related issue is whether a bank could reduce the three-year limit through a provision in the deposit agreement....