He walks outside and deposits the check remotely using his smart phone. Hauser appealed, but the Federal Appellate Court upheld the lower court. Although a stop payment was placed on check #12345, there is no evidence on the face of check #12345 of that stop payment. It’s negotiable, like a live check. Knowingly cashing or depositing a check twice on purpose is check fraud and can lead to federal indictments. Because the counterfeit and authentic checks looked identical, the lower court ruled for Triffin. All rights reserved. Their bogus nature would have been revealed by simply touching the checks. Shout It Like a Helium-Filled Gator: Don’t Limit Your Arbitration Agreements to Work-Related Disputes, Whaddaya Call It? When a customer electronically deposits a check, the bank creates an electronic image of that check, called a “substitute check.” This is what you sometimes see when you view your statement online. 127 Public Square, Suite 2000 Insufficient funds: A check can bounce when the sender issues what is known as a non-sufficient funds (NSF) check, which is one that an individual doesn't have enough money in their account to cover. The SuperBusinessCheck contains 16 security features, including heat sensitive ink, a true watermark and explicit warning bands. Payroll checks should expire in 10 days or less. Cigna’s bank dishonored the check on or about July 12, 1993, stamped it “Stop Payment,” and returned the check to Sun’s Market’s bank. It can be downloaded at safechecks.com. So let’s take a look. DOL Proposes New Independent Contractor Test, Avoid the Crocs! Recommendations: It is clear from this case that if a thief can get check stock that looks genuine, your company can be held liable for losses that may occur from those counterfeit checks. Mr. Triffin bought the checks, claimed Holder in Due Course status and sued Pomerantz. Staffing agencies, payroll agencies, or PEOs who issue a twice-cashed check are sometimes asked to make good on the same payment twice. The staffing company that issued the payroll check that was presented twice will have to pay the check cashing business due to “holder in due course” laws. They shouldn’t be. He can be contacted at greg@safechecks.com or by phone at (800) 949-2265. The check cashing store accepts and negotiates the check. Robert J. Triffin obtained the check from Sun’s Market, became the new HIDC, and filed this lawsuit against Cigna in August 1995, over two years after the check was returned unpaid. Staffing agency clients are increasingly pointing to a fraud committed by disloyal short-term employees. Mr. Hauser reviewed the checks and ascertained that, while the checks looked like his checks, they were counterfeits because none of the payees worked for him and he did not authorize anyone to sign those checks on his behalf. They then cashed the check again with a payday loan company. Part of the problem involves honest mistakes, which turned out to be the source of Rosales’ trouble. Further, a bank cannot be held liable for paying a stale-dated check. Under the Check 21 Act, the bank that creates the “substitute check” — the bank that allowed its customer access to the mobile check cashing app — is the bank that bears responsibility for any loss from the twice-cashed check. This article is provided for informational purposes. Companies should use checks uniquely designed and manufactured for them, or buy from vendors such as SAFEChecks (safechecks.com) that customizes every company’s check and never sells check stock entirely blank without it first being customized for the end user. The complete cases can be downloaded and viewed at www.FraudTips.Net/holder.htm. When a bank cashes a check, in effect it makes a short-term, interest-free loan. If a recipient (the Holder) is unable to negotiate the check, the Holder can sue the drawer (the check issuer) for the full face value of the check, and get a judgment against the drawer. Robert Triffin bought those checks and filed suit against Pomerantz. Dishonest Dave receives the check, holds onto it, and two weeks later calls Good Company claiming he never received the check. Pomerantz was protected by his checks. SAFEChecks“The Check Fraud Prevention Specialists”. A check that is six months old becomes a stale-dated check, and a bank has the legal right (but not the legal requirement) to decline payment on a stale-dated check. Pomerantz’s checks, but without the thermo ink on the back. He can be contacted at GLITSTER@aol.com and greg@safechecks.com, or by phone at (800) 949-2265. www.bakerlaw.com/toddhlebowitz Then, several months later, still in possession of the paper check, they take it to a branch or an ATM and cash it again. the face of check #12345 of that stop payment. Suppose the chip is a check, and the employee tries to cash it twice? Many companies opt for these solutionsbecause they are less expensive than controlled, high security checks (excluding legal fees and Holder in Due Course judgments). But, the store is not out the money because it is a Holder in Due Course. If you never cashed any checks, you had lost this check before and you just found it, then there was a check previously cashed by some other person but you and you are not liable to your employer. The Federal Reserve Board predicts that almost half of all mobile users will adopt mobile banking in one capacity or another. Mills nevertheless cashed the first check at Sun’s Market, and Sun presented the check for payment through its bank. Thanks, Electric Grandma! Recommendation: Use high security checks with overt and covert security features, including explicitly worded warning bands. Cleveland, Ohio 44114 This is true even if the drawer placed a stop payment on the check, or if the check was rejected at the bank as a Positive Pay exception item. Although Triffin lost on summary judgment at the trial court, the Appellate Court reversed the summary judgment and instructed the lower court to enter judgment in favor of Robert Triffin, with interest. Following are three cases decided by the Superior Court of New Jersey, Appellate Division. Please contact me with any questions. 370 N.J.Super. The answer is No. A retailer who knew Mr. Hauser became suspicious and called him. When a check is cashed fraudulently, there will be a bank investigation and the transaction will be reversed and the money recredited to the person who wrote the check. A thief obtained check stock that looked identical to ADP’s checks and created 80 counterfeit payroll checks identical to Hauser Contracting Co.’s, and cashed them all over town. Mr. Litster lectures on check fraud and embezzlement across the United States, and provides expert witness services in check fraud cases. For example, the recipient of the check may change the amount from $10 to $100. At the time, Hauser Co. employed Automatic Data Processing, Inc. (ADP) to provide payroll services, and a facsimile signature was utilized on all Hauser Co. payroll checks. You may accidentally deposit a check twice on your bank’s mobile app. Under the UCC, the recipient of the check is an HIDC and is entitled to be paid for the check. So today while going through a portfolio of mine I discovered a year old check from a job I use to work at up until several months ago. 301, 851 A.2d 100, 2004.NJ.0000281, This is one of the few cases Robert Triffin lost. Because the check casher failed to authenticate the checks, it did not obtain Holder in Due Course status, and Triffin could not claim what the check casher did not have. Cut Off This, But Not That! A Holder in Due Course can sell his or her rights to the check to … The bank that cashed it refused it and sent it back to us on August 3rd. The best way to protect your company from losing this type of lawsuit is to cause the first check to expire before re-issuing a new check, for example, in 25 days. Never Surrender: Appeals Court Grants Reprieve for Ride Share App Companies; Focus Turns to Prop 22. SAFEChecks sells high security checks, secure check printing software, and Positive Pay file formatting software. In this case, Mr. Triffin appealed a trial court’s summary judgment decision dismissing his complaint for payment of a Cigna Insurance Company check that was transferred to Triffin by a Holder in Due Course after Cigna had stopped payment on the check. Superior Court of New Jersey, Appellate Division, A-163-00T5. If you lose a check you have signed without filling in the name of the recipient, you should stop payment on the check to try to prevent it from being cashed. California’s AB 5 Has Been Repealed, Sort Of. Mr. Hauser executed affidavits of stolen and forged checks at the bank, stopping payment on the checks at issue. – Compliance Tips Visit www.PositivePay.Net to learn more about Positive Pay. You usually can’t get your money back if someone fills in his or her own name and cashes the check. If the double dipping occurred through an electronic “substitute check,”, they can point to the Check 21 Act, specifically 12 USC §5004 , and argue that the double-dipper’s bank is properly accountable. Each agency stated that it cashed the checks for value, in good faith, without knowledge that any of the signatures were unauthorized or forged. Pomerantz Staffing Services used high security checks that included heat sensitive (thermochromatic) ink on the back and a warning banner on the front that said, “THE BACK OF THIS CHECK HAS HEAT SENSITIVE INK TO CONFIRM AUTHENTICITY.” Someone made copies of Pomerantz’s checks, but without the thermo ink on the back. For over 30 years he has lectured to and consulted with hundreds of financial institutions, corporations and government agencies around the world, including the FBI. Triffin appealed because Triffin almost always wins on appeal. SAFEChecks and the Abagnale SuperBusinessCheck, designed by Frank Abagnale and available through SAFEChecks, are both strictly controlled check stock. The payday loan company subsequently sent me a letter stating that they are a Holder in Due Course under UCC 3.302, requesting payment for the amount of the check. The trial judge granted Pomerantz’s motion and dismissed the case. A Holder in Due Course has 10 years from the date a check was issued, or three (3) years from the date the check was returned unpaid, to sue the drawer (Good Company) for recovery of the full face value of the check, UNLESS THE CHECK HAD EXPIRED BEFORE THE RECIPIENT ACCEPTED IT (in this case, the check cashing store is the recipient.) Sun presented the check for payment through its bank. Mills falsely claimed he did not receive it due to an address change, and requested a replacement. Both are strictly controlled, high security check stock that were designed with Frank Abagnale, one of the world’s foremost authorities on fraud prevention. A Holder in Due Course can sell his or her rights to the check to anyone, at any time, and at any price. – New Developments & Analysis I would recommend that you ask the bank and your employer to provide a copy of the prior cancelled/paid check to you. Each check was payable to a bearer for a fixed amount, on demand, and each check appeared to have been signed by Mr. Hauser, through the use of a facsimile stamp. The Court found that lack of authorization was a separate issue from whether the checks are negotiable instruments. However, in many cases the payee (the person who wrote the check) is held liable for causing the problem. Many checks have verbiage printed on the face that says: VOID AFTER 90 DAYS or VOID AFTER 180 DAYS. Section § 3-302 of the Uniform Commercial Code defines a Holder in Due Course as “Othe holder of an instrument if: (1) the instrument when issued or negotiated to the holder does not bear such apparent evidence of forgery or alteration or is not otherwise so irregular or incomplete as to call into question its authenticity; and (2) the holder took the instrument (i) for value, (ii) in good faith, (iii) without notice that the instrumentOhas been dishonored, (iv) without notice that the instrument contains an unauthorized signature or has been alteredO” The UCC allows a Holder in Due Course full transferability of rights to assure the holder a free market for the instrument (§ 3-203). We can cash checks and money orders in any amount up to and including $5000. Fraudsters haven’t directly targeted mRDC users’ devices on a large scale; however, cases of mobile users double-depositing the same check at multiple banks, or cashing the check at a check cashing store after depositing via a smart phone, are growing significantly. All 18 checks bore a red and green facsimile signature stamp in the name of Alfred M. Hauser. We will guarantee that "mobile deposit only" is written on the back of the check under the endorsement, but that will only work if it's caught before the paper check is deposited. Many companies’ checks expire in 90 or 180 days. Scammers often convince victims to deposit fake checks and forward a portion of the cash to them. Banks can refuse to cash a check, even a check that is issued by the government. On July 7, 1993, a check for $484.12 had been issued for workers’ compensation benefits to James Mills by one of Cigna’s companies, Atlantic Employers Insurance Company. There are two important items to consider about stop payments. The bank gives out cash immediately, but it may not receive offsetting credit for the cashed check for a day or more. These protections generally do not apply if you signed a blank check. At that point the check cashing store becomes a Holder in Due Course. Recommendation: Make a check “expire” before replacing it, or you can be held liable for both checks. Both were cashed…and then cashed … Three Federal Appellate Court cases illustrate the far-reaching power of Holder in Due Course. Many companies print “Void After 90 Days” or longer, but cannot reasonably wait that long before re-issuing a check. State penalties for check fraud vary, but depending on the amount of the check in question, check fraud may come with a misdemeanor or felony charge, a fine, and/or jail time. When While the above case clearly illustrates what a Holder in Due Course is, the case does not deal with check security features, or the lack thereof. Mr. Triffin bought 18 of these checks totally $8800 from four check cashing agencies, claimed HIDC status, and sued both Mr. Hauser and his bank for negligence or not safeguarding the payroll checks and facsimile stamp. We returned it through help from Fed, with the proper documents on August 4th. Each check bore Pomerantz’s full name and address and a facsimile signature of “Gary Pomerantz.” Printed on the face of each check was a warning: “THE BACK OF THIS CHECK HAS HEAT SENSITIVE INK TO CONFIRM AUTHENTICITY.” Without examining the checks as suggested by this warning, the store cashed the checks, which the bank returned unpaid and stamped: “COUNTERFEIT” and “DO NOT PRESENT AGAIN.” (The fact that the bank caught checks of such low dollar value suggests that Pomerantz was utilizing its bank’s Positive Pay service. My employer has called me to tell me that my payroll check was cashed twice. If a company wrote a check to an employee, and the check was cashed at check cashing store and it bounced twice, is the employer responsible for paying back the bounced check? – Updates. Good Company places a stop payment on check #12345 and issues a second check for $5,000 payable to Dishonest Dave, who now has two $5,000 checks payable to himself. Note:  The Check 21 Act only applies to electronic double dipping. Issue: You May Be Held Liable For Checks You Did Not Issue or Authorize. More than 14,000 financial institutions, corporations, and law enforcement agencies use his fraud prevention materials. Most companies buy check stock from vendors that sell the identical check stock entirely blank to other companies, totally uncontrolled, thus aiding the forgers. Companies should print on the face of the check a statement declaring a date after which the check is no longer valid, such as “THIS CHECK EXPIRES AND IS VOID 20 DAYS AFTER ISSUE DATE.” If a check is lost, the payee would have to wait 20 + 2 days before the check is reissued. ), Buckle Up? Unfortunately, it does and you may be liable to Checks ‘R Us for the amount of the original paycheck, even though you had placed a stop payment order on it and Ralph had previously cashed the replacement check. This case clearly illustrates the value of check security features, a properly worded warning band, and a controlled check stock. Answers: So this would be double presentment. It also found that because the checks appeared to be genuine, Hauser Co. was required, but had failed, to show that the check cashing stores had any notice that the checks were not validly drawn. As you will read in the New Jersey Appellate Court case between Robert Triffin and Cigna Insurance, under the UCC a Holder can force a company to pay them the face value of the check. Cashing the same check twice. Pomerantz counter-sued and won! The bank is liable to paying a check that has been materially altered. While this practice would be very inconvenient for the recipient, there is no other way a company can protect itself from a Holder in Due Course claim. Louise Moon Rosales had two checks cashed twice. I issued a check to an employee. They cashed it once, presumably by mobile deposit. He is an associate of Frank Abagnale, and is publisher and editor of Mr. Abagnale’s publication, The Fraud Bulletin. Cigna placed a stop payment on the initial check and issued a new check. All 18 checks were returned unpaid, likely caught by Positive Pay. “Void After XX Days,”), the recipient/purported “Holder” has no legal standing as a Holder In Due Course, and cannot claim that legal status. Thereafter, Mills cashed the initial check at Sun’s Market, Triffin’s assignor, before the stop payment notation was placed on the check. Mr. Hauser reviewed the checks, which looked just like his, and confirmed the checks were unauthorized and the payees were not his employees. Sun’s Market posted the check on a bulletin board in the store where it stayed for about two years until Robert Triffin visited the store and purchased the item at a deep discount off face value. In October 1998, Alfred Hauser, president of Hauser Co., was notified by a retailer and Somerset Valley Bank that several individuals were cashing what appeared to be Hauser Co. payroll checks. The Bank subsequently received over 80 similar checks drawn on Hauser Co.’s account, valued at $25,000. Mr. Triffin then sued Somerset Valley Bank and Hauser Co., contending that Hauser Co. was negligent in failing to safeguard both its payroll checks (which apparently looked like legitimate ADP checks) and its facsimile stamp, and was liable for payment of the checks. Second, a stop payment is typically good for only 180 days. At that point the check cashing store becomes a Holder in Due Course. This is how legal exposure to a Holder in Due Course claim can be and is created. Our industry is faced with an epidemic of returns for duplicate presentments where a payee will deposit an image of their check (using their phone app), then bring the original to the check casher. © 2017 Todd Lebowitz, posted on WhoIsMyEmployee.com, Exploring Issues of Independent Contractor Misclassification and Joint Employment. They cashed 18 checks totaling $7000 at Friendly Check Cashing Company. Under Check 21, the first presentment of the check (via smart phone) can be charged back to the bank of first deposit (BOFD) under a Breach of Warranty claim (because of the second presentment) for up to one year from the date the injured party discovers the loss, even if he doesn’t discover the loss for 6 months or more. After that time, the stop payment drops off the bank’s system and is no longer monitored. 199, 687 A.2d 1045 (App. They don’t think to place a Stop Payment on the first check because it is in their possession. Mills received the check, but falsely claimed to the issuer that he had not due to a change in his address. Entities using Remote Deposit Capture or Mobile Remote Deposit Capture (whether organizations or individuals) are essentially acting as agents of the bank when they image checks and deposit them remotely. In July 1993, Cigna Insurance issued James Mills a Worker’s Compensation check for $484. over two years after the check was returned unpaid, Such security features will also help prevent other kinds of check fraud, for up to one year from the date the injured party discovers the loss, Holder in Due Course - Summary and Detailed Explanation. But, she warns, wait until those checks clear, too. Also, Triffin did not explain why the check casher did not examine the checks for heat sensitive ink as directed on the face of check. Check #12345 hits Good Company’s bank account, and is returned "payment stopped" to the check cashing store. We have the ability to monitor our current and previous payments from payroll . Frank Abagnale President, Abagnale and Associates www.abagnale.com, Greg Litster President, SAFEChecks www.safechecks.com. Involves honest mistakes, which also did not look for the thermo ink rules for Independent. 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On July 11, 2013 under Employment Labor Law, Oklahoma checks drawn on Hauser Co. ’ checks! May be held liable for both checks catch me if you are, then deposit the check... To use high security, controlled check stock 851 A.2d 100, 2004.NJ.0000281 this! Long before re-issuing a check fraud and embezzlement across the United States, Sun. Because the second check was refunded by the student they cash a paycheck on their phone the SuperBusinessCheck contains security! Them online, and is no longer monitored stop payments a substitute then... From its check stock far-reaching power of Holder in Due Course notifications of New posts by email s and! Not on Positive Pay enforcement agencies use his fraud prevention materials as this case illustrates, Placing a stop on! And sent it back to us on August 4th users will adopt mobile banking app on their phone and the. Johnson: Robin @ safechecks.com as instructed, they could have determined the checks are instruments... 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