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PHIL & KATHY'S, INC. v. SAFRA NAT. BANK OF NEW YORK
United States District Court, S.D. New York (2009) | 595 F.Supp.2d 330
TL;DR: A bank received a wire transfer for a non-existent beneficiary. Before the transfer was automatically cancelled by law, the sender's bank amended it. The court held the receiving bank properly paid the amended transfer, as the UCC allows for amendment within a five-day window.
Legal Significance: Under UCC Article 4-A, a payment order to a non-existent beneficiary is not immediately void. It remains active and amendable by the sender for five business days before being cancelled by operation of law, placing the risk of duplicative orders on the originator and its bank.