ICL – Duplicates: The Never-ending Story

ICL – Duplicates: The Never-Ending Story

Perfect. Welcome back everybody for our last session. This one is really going to be pretty much of a review of the kind of things we’ve talked about, and hopefully the legal references and all of that stuff will be very familiar to you. We’re going to go through all kinds of scenarios that we’ve seen in duplicates, and duplicates don’t go away. Hey, that’s why we call it The NeverEnding Story. Although the Fed recently, periodically publishes the number of adjustments it handles and encoding errors have exceeded the paid adjustment error. So, that’s a cool thing. So, we’re back to encoding errors, being the most common kind of adjustment going through the Fed and duplicates have dropped down. So, maybe we’re making some headway.

So, first thing I want to remind you. I’m not an attorney. I’m not giving you legal advice and the scenarios that you’re going to see in this deck are hypothetical They’re based on questions that we’ve gotten over the years situations that we’ve seen some that seem really bizarre, but they kind of repeat themselves. Some of these might look familiar to you. But we try to address every possible kind of scenario so that you know how to act. And again, you want to make sure that in certain circumstances, you may need to consult your legal counsel to know exactly what to do.

Having said that, these are essentially the reviews that we’re going to cover today. We’re going to look again at that reg CC, no double debit warranty. We’re going to look at the RDC indemnity. We’re going to look at the paying returning bank warranty it makes when it returns checks. We’re going to look at different ways and different considerations for how to resolve duplicates. And then we’re going to kind of review again, what we talked about last week, how holder in due course can impact your decision as a paying bank when you’re deciding what to do with a duplicate. So, let’s review again in reg CC 229.34 (a)(ii), that’s where you’re going to find, the no double debit warranty and it does not use the word duplicate. And there are three warranties that live in this regulation, the first being that when you present an image of a check, or what reg CC calls an electronic check, whether it’s forward or return, you are warranting that it accurately represents all the information on the front and back of the original paper check. And also, it says nobody is going to receive the transfer presentment return or otherwise be charged for an electronic check or an electronic return check, the original check, substitute check, or paper or electronic representation of a substitute check, such that the person will be asked to make payment based on a check it has already paid and that’s an important warranty to remember. That applies to every single bank that presents an image to a paying bank, whether multiple banks are presenting the same image, everybody’s making this warranty. So that’s an important thing to remember in and this is an important regulation to have saved in your favorites.

So, what this warranty does, it protects a bank or persons from having to pay the same check twice. And I should say that in regulations and in UCC, when you see the word persons that really means entity. It’s not implying necessarily that it’s a flesh-and-blood individual. And the other thing that really needs to be understood is every bank that transfers or presents an electronic check makes this warranty. The warranties are made to everybody in the collection chain, including the banks and the depositing customers. The warranty is not made to banks outside of the collection chain; for example, when a bank presents a check to a paying bank, an image of a check, it makes this warranty. But it’s not making this warranty to any other depositary bank. Then we looked at the RDC indemnity text last year, hahaha, or last week and basically reviewed that the bank that truncates the check and sends on an image, whether it truncates it at the teller station or lets its customer truncate it and takes the image for a deposit, is a bank that doesn’t receive the original check but get settlement for it. In other words, it gets paid for it when it presents it to the paying bank and doesn’t get a return or adjustment back. That bank indemnifies a depositary bank that takes the paper check or loss incurred by that depositary bank if that loss is due to that check having already been paid. So that paper depositary bank gets an adjustment or a return of that check as having already been paid; that bank is indemnification by the RDC bank.

But if that depositary bank that took that paper check took it with a restrictive endorsement, that was inconsistent with the means of deposit, it is not covered by this indemnity. So, if you are a depositary bank that accepted a paper check, you have to meet four conditions. First. the RDC depositary bank has to be the truncating bank, didn’t receive the general check, got paid for it, and it wasn’t returned or adjusted back to them. So, they received settlement. The paper bank has to have incurred a loss. So, it could not charge back its depositor. Its depositor’s account was empty. Now, it suffers a loss, and it has to have the original paper for that it received the original paper for deposit. And again, that original paper check must not have a restrictive endorsement that is inconsistent with that paper deposit. For example, a lot of RDC depositary banks require their depositing customers to endorse the check that they are remotely depositing or remote deposit only, and it’s good to maybe make that even a little bit more restrictive for mobile deposit only to ABC bank. So if a paper check takes that paper check with that restrictive endorsement, they’re excluded from making this indemnity claim. We talked about restrictive endorsements, that’s defined in UCC 3-206. It limits the negotiation, essentially, of that check to a specific way, for example, for deposit only or for mobile deposit only; more restrictive yet, for mobile deposit only to ABC bank.

Now, we also looked at holder in due course, which is defined in UCC 3-302. And that’s the holder who has possession that took the item in good faith, took it for value, and without notice that the item was overdue, which means more than 90 days from the issue date, and without notice that it has already been dishonored. For example, it’s a substitute check. If any party accepts that whether it’s a check casher or another depositary bank, they don’t have holder in due course rights, and obviously they have to know, make sure that the check wasn’t altered, and they have no notice that the drawer’s signature is not authorized. And then without knowledge of any claims against it, an example of that could be that, in fact, the endorsement says for mobile deposit only, so it knows that there are potentially claims against that job. Now, holder is the person who is in possession of that negotiable instrument, and it’s either payable to them or payable to bearer that used to be a little bit more common to make checks payable to bearer, which meant that anybody who had the check could cash, it businesses would sometimes, if they wanted to have someone go cash a check for petty cash, would just make it payable to bearer so that the individual wasn’t the named payee but essentially write a check to Nikki and it’s payable to her and I give it to her, she is now the holder.

Now when the paying bank wants to return a check for any reason, it has to do so timely and when it does it, when it does return the check, it makes a warranty that it returned it timely. And there are two clocks that start ticking when the paying bank receives the check, when it’s presented to the paying bank, they have to, if they’re going to return it, get it out of their shop by midnight the day after presentment so that it gets back to the depositary bank by the second business day following the banking day in which the check was presented to the paying bank. So, when you look at this warranty, someone asked me this question, I thought it was an interesting question. it said, why does it say “or”? It warrants that it returned it within the midnight deadline OR within the reg CC expeditious return and the point really is that when the paying bank returns a check? It has to get back to the depositary bank by 2 p.m. the second business day following the banking day on which the check was presented. So, a bank may have an agreement where it delivers the returns directly to the paying bank on the second business day. So that’s the main point. And as we talked about in the past, those warranties don’t apply to Treasury checks, U.S. Postal Service money orders, or a check drawn on a state or unit of local government.

Are there any questions about what we talked about so far?

Nothing yet.

Nothing yet.

All right, so here’s a little graphic that you can just pull out of your handout and have it in front of you. It, what it does is really demonstrates the expeditious return example. Here, the check is deposited on Monday. So, Monday, that depositary bank sends it out in their cash later at night, gets to the paying bank on Tuesday, and the clock starts ticking. So, they post, try to post those checks on Tuesday night. Wednesday morning, the bank is looking at all of the NSFs, all of the unposteds, account not found, payment stop, that kind of thing. And they need to return them by midnight that night. That’s the UCC midnight deadline so that it gets back to the depositary bank on Thursday by 2 p.m. their time. Now if Tuesday’s a holiday everything gets bumped over one more day. So Tuesday’s a holiday. The paying bank gets it on Wednesday. They have to get it out of their bank on Thursday so that it gets to the paying bank on Friday. Okay, so this little visual can help you understand the return deadlines.

So, let’s look at some scenarios with duplicates. So, as we said, remember the reg CC no double debit warranty. Here we have an example of a check being presented by depositary bank A and also by depositary bank B. Which bank can the paying bank make the claim to? Either one, because remember, they all made the warranty. I sometimes get questions from a bank that says well, I deposited or I presented that check first. Why are they doing the adjustment back to me? Because every bank that presents a check to a paying bank makes that warranty that no one’s going to be asked to pay it twice. We looked about at holder in due course claims last time, a paying bank pays the same check twice. It’s accepted by BOFD A as an RDC deposit, and it’s accepted by in paper at a check casher or maybe a liquor store or something like that or by another depositary bank. And it doesn’t have a restrictive endorsement. That party, if they met all the requirements is now a holder in due course. So what happens, the drawer’s account is charged twice for the same check. The paying bank relies on that no double debit warranty. But it returns it back to somebody who has holder in due course rights. And then the drawer is forced to pay it. They are taken to court or potentially threatened to be taken to court. And now they paid that same check twice. The duplicate, or in this case, where they were charged for the first presentment, and then paid the holder in due course claim, they paid it twice. So that first check was not properly payable. Properly payable, means under UCC 4-401, authorized by the customer. Customer didn’t authorize and doesn’t authorize a bank to pay the same check twice. So, they say to the bank, I’ve had to pay this twice. Paying bank reimburses them, and they can make the no double debit warranty, the duplicate presentment warranty breach claim as an adjustment back to the other presenting bank. So, let’s look at how this flows. The depositor cash deposits a check through remote deposit to RDC depositary bank A, presents it to the paying bank. Then he takes that paper check and cashes it at a check casher, liquor store, grocery store, whoever cashes checks.

That check casher and this example doesn’t RDC deposits to depositary bank B, who sends it on to the paying bank as an electronic check. And typically, banks in their duplicate detection might just automatically return the second presentment. So, in this case, it went back to someone who had holder in due course rights. They met all the conditions of holder in due course. They had the paper and that was that check casher. So he makes the HIDC  claim against the drawer, threatens them, the drawer pays it, and now they paid the same check twice. Paying bank reimburses that drawer, and they do what they probably should have done in the first place. Is the just it back to the RDC depositary bank. It’s not always obvious to a paying bank which is which, but we’ll talk about that. We have talked about that, but it’s always bears repeating, when that paying bank saw that duplicate, it was worth looking at the endorsements of both of the checks presented, to see if they can determine if one of them might have been a check casher. Keeping in mind that not everybody qualifies as holder in due course. For example, that check may have been accepted or cashed by a check casher or taken by a depositary bank on the 91st day beyond the issue date. In which case that check was overdue, and they don’t have holder in due course status. So when someone claims holder in due course status, do some research, make sure that they actually do. Make sure that that paper check they accepted did not bear a restrictive endorsement.

So, return or adjust, this is where research is important because the depositor of the paper check may have holder in due course rights. If the depositary or the paying bank adjusts the, really, the source of the duplicate, gets it back the RDC depositary bank, that’s really where you want that duplicate to go back to because that RDC depositary bank has a customer who caused the duplicate. Their customer stole from the drawer, and that’s where you want it to go back to. If that RDC depositary bank can’t recover from their depositor, that’s their loss. They gave RDC service to someone who shouldn’t have had it. And this sort of, this really mirrors FFIEC’s point of view from the very beginning of RDC. FFIEC is the Federal Financial Institutions Examination Council, and it consists of all of the regulators, and they basically made the opinion that the party that introduces the service that facilitates the fraud is the party that should be ultimately responsible. And that’s where the RDC indemnity really came into play. So, you remember that either duplicate check can be adjusted, as paid if exchange through the Fed or duplicate under the ECCHO rules, but it’s well worth doing some research. Maybe you want to present or return or adjust, rather, the first presentment because – think like a fraudster, if I am going to negotiate that check twice, Nikki writes me a check, I deposit it with my bank through RDC, and then later in the day, I go to a check casher, which one is most likely to be presented to the paying bank first? Probably, this is no science, but probably, the RDC depositary bank because it’s going to go out in their cash letter the same day they accepted it. Whereas the check casher may not be depositing that into their bank until the following day.

So, here we have it, [untelligible].

Speaker 2: We have one question here.  Could check adjustment be done expeditiously by the second banking day, like a return?

Speaker 1: No! and that’s an excellent question. So, let’s go back to reg CC, when a depositary bank makes that warranty that no one’s going to be asked to pay the same check twice, that warranty lives for one year; reg CC has a one-year statute of limitations. So the paying bank may learn of a duplicate 90 days after it was presented, six months after it’s presented, 12, 11 months after it’s presented. It can do an adjustment up to or actually hold the depositary bank responsible for the warranty breach for up to one year. Now, adjustment platforms have timing. If you go through the Fed or through ECCHO adjustment, either one, both of them require you to do that adjustment within 90 days of the presentment date to get entry. That means you get credit right away. After the 90 days, you can do an adjustment without entry for, I think, a period of up to 150 days. And what that means is that sends a message to the depositary bank that they have to pay up. Or you deal direct and remember that the one-year statute of limitations. So that’s a good question. Any others?

It’s the only one so far.

All right, we have met Mr. Blue Guy, who is really not the kind of guy you want to give an account to, but both BOFD A and BOFD B have given this guy an account and BOFD A has given him RDC service. So, he deposits a check through remote deposit, then he takes that same check and deposits that at BOFD B in paper. Now, paying bank detects the duplicate, maybe because their customer told them that or because they have duplicate detection but before they automatically return this back to the second presentment or two, if they can determine based on the endorsement, that it’s the check casher. The best thing to do as we talk is get it back to the RDC depositary bank. That really is the source of the duplicate.

Now, I warned you, we’re going to go through some weird scenarios here. If Nikki writes me a check and now, I have her account information. I have her signature. I might just choose to counterfeit that check and maybe I’m not the smartest counterfeiter, so I use the same check number. So, I deposit that check through RDC. I take a picture of that physical check through RDC. And then I take a picture of another physical check, one of the counterfeits. And send that through RDC and then I do it three, four, or five more times. In paper. So I take, I counterfeit Nikki’s checks and I create multiple counterfeit checks. So are these duplicates? They’re not really duplicates because they are different pieces of paper. A duplicate is the same image of, of a single paper check that gets presented multiple times. So, the duplicate would be the images of one paper check. When multiple paper checks are counterfeited, for example, they’re technically not duplicates. So, what does the paying bank do in this case? Well, the paying bank isn’t always going to know that those were all separate paper checks so they may try to do a duplicate adjustment for example back to RDC depositary bank 1, who says, wait a minute, I have the physical paper here. They do it to RDC bank 2 and they say, wait a minute, I actually have the physical paper. So that can happen. There’s weird scenarios. So if you catch it in time, you would return it. If you got it through an ECCHO exchange, you could do a rule 9 claim. Or maybe they’re ECIs, which would be odd because well, ECIs aren’t eligible for exchange. Any questions about that scenario?

I should add, since we’re here and it’s a little bit different, you probably all seen situations where businesses issue checks and they might print them off by computer. They’re doing their accounts receivable, check payment printing and something happens in their system and they print the same check twice. They only mean to issue it once, but they are two physical pieces of paper with two made-payable to a payee and the check numbers are generally the same in that scenario. When those hit the paying banks, those technically aren’t duplicates because they are two physical pieces of paper. So anyway, keep that in mind.

Another scenario that I’ve heard about is a depositary or a paying bank, who received a check from another bank through RDC, charged their customer’s account, and then Mr. Blue Guy went into the paying bank and actually cashed the check. Is that a duplicate scenario? So when the paying bank discovers that they paid that duplicate, can they do a paid adjustment? And they really can’t because the point is there wasn’t, there weren’t two presentments of that check. The paying bank had already paid that check when it was presented by BOFD and then it cashed it again. Who is in the best position there to know that the check had already paid? The paying bank. So, it’s really worth double-checking that when your teller cashes a check, does your system do a search of that account history, to see if that check has already been paid. In that scenario, this is where the paying bank has a check that it had already paid and it’s going to take the loss.

So the RDC indemnity, we kind of walked through that before. Depositor deposits the check through RDC, and then he takes that paper without a restrictive endorsement in this example to another depositary bank where he has an account, check gets returned or adjusted back by the paying bank, has duplicate, they can’t recover from the depositor. Now, they can make the RDC indemnity claim because they accepted that paper check in good faith. There was no restrictive endorsement on it, and they suffered a loss because it was returned as a duplicate. And that is exactly an illustration of the terms of the RDC indemnity.

So let’s look at another example, where Mr. Blue Guy, he’s at it again. He deposited a check through RDC. Then he took the paper check to his other bank with a blank endorsement, and the paying bank returned it as duplicate. They couldn’t recover, they make the claim. Now, depository bank says, wait a minute. I see a restrictive endorsement on the image that we accepted for deposit. So can I disclaim this RDC indemnity claim? Well, that all depends. Remember that seeing that restrictive endorsement on the image that you accept, as an RDC depositary bank, is not evidence that the paper check itself has the restrictive endorsement. So you don’t just automatically disclaim it because you see the restrictive endorsement on the image that you accepted. What’s key is what does the endorsement or the back of the check of a physical piece of paper that the other bank took, does it bear a restrictive endorsement or not? We all know how fraudsters work. You require as a depositary bank that if you are going to accept a check through RDC, you want your depositors to put a restrictive endorsement on that check, but what they do is take a picture of the actual check and then instead of taking a picture of the back of that physical check ,which bears a restrictive endorsement, they that restrictive endorsement on another piece of paper that’s the same size and now it’s past your due diligence when you accept that RDC deposit and you say, yep, he met the restrictive endorsement requirements, when in fact, you were scammed.

Any questions about that so far? Going to take that as a no.

All right, so here’s an example where there is no restrictive endorsement, depositary bank makes the claim. Here’s an example where that that little scam that we just talked about happens. So, the depositary bank accepts the paper check. But it accepts it with a restrictive endorsement. It says, for deposit, for mobile deposit only to RDC depositary bank. So, paper depositary bank should not have accepted that, it’s adjusted back to them and surprise, surprise! depositor’s account is empty. So, they think, I’m going to make an RDC indemnity claim. Now when making that RDC indemnity claim, you’ve got to include a copy of the check as you took it, front and back. So they make the claim RDC depositary banks as mm mm. There’s a restrictive endorsement on that paper check that you accepted. I’m going to disclaim it. And again, the point there is depositary bank should not have accepted that check with a restrictive endorsement that said for mobile deposit only to our RDC depositary bank. Paper depositary bank is not entitled to enforce that check. First of all, you should not accept that. So, that’s an important thing that you want to make sure your front line understands. Look at the endorsements on paper checks being deposited. If they bear a restrictive endorsement, that’s inconsistent with that paper deposit, don’t accept it, because if it comes back to you as duplicate your RDC indemnity claim will fail, and if you can’t recover from your depositor, you will take that loss. All right. So you are that depositary bank who took the paper. How do you find out who the RDC depositary bank is so you can make a claim against them? So that was exchanged through the Fed, you do an INFO ITYP. And what the Fed does is provides the depositary bank endorsement on the electronic image. So don’t use source of receipt. Instead use INFO ITYP. And to make that claim, you want to complete it. You want to do this INFO ITYP within 90 days of having gotten that paid adjustment. If you got this check through an ECCHO exchange, then you’re going to submit a source of receipt. So don’t do a Fed source of receipt. But if you got through ECCHO, then you, you do want to do source of receipt and what that, what that does is a paying bank will identify the depositary bank who received settlement and that’s an important condition. And again, the paying bank has to respond within 20 days to your source of receipt item. And then you make that claim, again, within one year of that return, cash letter date, remembering that reg CC has a one-year statute of limitations. So, we have multiple banks and this is not uncommon for the depositor to use multiple banks to cash, er, deposit the same check three or more times. In this example, the most I’ve heard of was 12, and I find that really amazing. So, depositor doesn’t RDC deposit to bank 1 to bank 2, bank 2, gets adjusted back. So bank 2 no longer had settlement. Now, he takes that paper check to paper depositary bank and that gets adjusted back as a duplicate. They can’t recover from that depositor. Who do they make the claim to? Well, they might try, you know, they learn from the use of the Fed or from the ECCHO-governed exchange that RDC depositary bank number 2 received settlement, except they didn’t receive settlement that was adjusted back to them. So the point here is, when you do that INFO ITYP or the ECCHO source of receipt, what you really want to know is who received settlement, who got paid for that item, and in this example, depositary bank 2 actually didn’t get paid for that item. It was adjusted back to them.

So let’s walk through this again, where the adjustment needs to go. The RDC indemnity claim needs to go, is to the bank that received settlement. Okay, I’m going to stop there. I think I saw a question pop up.

Speaker 2: Yeah, you did. So, it says, our vendor provides us with a cash letter report, that lists the bank of first deposit for each item. Should we take that as the true depositary bank, or should we still confirm through fed INFO ITYP I-TTYP?

Speaker 1: Hmm. That’s interesting. I’ve not heard of that but in the format of every electronic check that is presented, every bank has to identify itself as the depositary bank. So, if your vendor, your core processor tells you, okay, this check was presented by ABC bank, this check was presented by XYZ bank, then essentially, you know what you need to know in order to make that indemnity claim. That’s very interesting. That’s the first I’ve heard of that, but it makes sense. It makes sense because that information of the depositary bank is included with the check, but as I’m thinking about this, what that won’t tell you is who received settlement. So, for example, it tells you that you’re the paying bank. You got a check from RDC bank 1 and RDC bank 2 the same check. And, now] I’m sorry, you’re the paper depositary bank and your system tells you that the paying bank received these checks, not only from you but also depositary bank 1 and 2, but it won’t tell you if paying bank adjusted it back to RDC 2. So really the purpose of making doing that INFO ITYP or that source of receipt is to find out who got paid for that and that’s something that your system is not going to know. That makes sense. That’s a good question.

All right. I think we went through this already. All right, so when it comes to duplicates, your key takeaway is who can make the duplicate warranty claim, the paying bank that receives the the request that it has already paid a check. That’s the that’s the party who is provided the warranty, who makes the duplicate warranty every bank that presents a check to a paying bank. So again, it doesn’t matter the order. And in the examples that we looked at in some of the scenarios, it may be that as a paying bank, you want to make the duplicate warranty breach claim, the paid adjustment claim, back to the first presenter, not the second one, but you can do it to any one of the banks or all of them if there’s multiple banks. All but one obviously, you want to pay one. So, a depositary bank cannot make a warranty claim to another depositary bank. That’s another important thing to remember. The warranty begins with a depositary bank that introduced the check into the collection process. That’s every depositary bank.

All right. So when we talk about that RDC indemnity, remember that, that paper depositary bank has to experience a loss in order to make that claim. It can’t call a loss, its refusal to charge you back to its depositor. That’s not a loss. That’s an expense. So, if you are a depositary bank, you took that paper check, you got it returned as having already been paid, and you choose not to debit your depositing customer who may have the funds. Then you didn’t experience a loss. So that’s an important consideration. The RDC indemnity also applies to that depositary bank that took that paper check. It doesn’t apply to check cashers or other non-financial institutions that accepted that paper check. So, let’s say you bank a grocery store that also cashes checks, and you, they took the physical paper. They deposit it with you through remote deposit, you get that thing returned or adjusted back as having already been paid. And now, you charge it back to that grocery store. And that’s a loss to them. That’s not the party that receives this indemnity. It’s the, it’s the paper depositary bank. If if they deposited that paper with you, and it was charged back to you as having already been paid and you attempted to debit that grocery store who didn’t have any money, then again, you, the depositary bank, you are given that indemnity. But if they have the money in their account and you charge it back, yes, it’s a loss to them, but they are not the party that receives this indemnity. Okay, and again that restrictive endorsement cannot be on that physical check, if you’re going to make an RDC indemnity: claim.

Any questions about that before we go into reviewing holder in due course.

Speaker 2: So far, so good.

Speaker 1: All right. Now, we talked about the holder. You know, I write a check to Nikki. She’s now the holder. Nikki goes into her, local bar to cash it. And that bar cashed it, and he met all the terms of holder in due course. Now, essentially, what happens is that legal right to enforce that check went from Nikki to the bar. And that’s where holder in due course comes in. Now they have the paper and if they met all the requirements, they are holder in due course. So it’s important that, you know, all of those requirements that we talked about that are found in UCC 3-302. Because not every check casher, for example, I’ve seen this multiple times, who claim holder in due course rights, don’t actually have them because they didn’t meet all the conditions. So, it’s important to know when someone gets a holder in due course claim, you’re, for example, if you’re a paying bank, your customer will, got to make sure that they actually have holder in due course rights.

All right. That’s the end of my story. Are there any questions about that? I think some of this was repetitive for you, but it bears repeating. It’s important to understand the rules and the regulations that govern check. It’s important to understand all the strange things that can happen with duplicates. Try to think like a fraudster when you’re a paying bank, you’ve got multiple checks being presented again and again the same check presented again and again. How did the fraudsters do that? And what do you want to do? And who is going to have holder in due course rights? And so forth and so on, if you’re a depositary bank, you want to make sure that you know what your rights are and what conditions you need to meet in order to make a hold, an RDC indemnity claim. Remember, your customer is not the party that receives that indemnity. It’s the depositary bank that takes that paper check without a restrictive endorsement and suffers a loss because it was returned or adjusted back as duplicate. Not your depositor.

So, if you are an ECCHO member, you can go to our website and look at other education sessions. We have all kinds of other resources out there. If you happen to be an NCP, that earns continuing ed credits. And as always, if you have questions about this session, give me a call. I’ll happy happy to talk to you about it. If you are an ECCHO member, you can get in touch with me about any kind of question that you have.

Did I see a question pop up?

Speaker 2: Nope, just a statement. It says excellent series of webinars. Thank you, Dal and Nikki.

Speaker 1: You are welcome. Thank you very much for your attention. I appreciate that. You have attended these week after week after week, and I hope I hope that all of this knowledge now gives you the power that you need to navigate through all the risks of check. Good luck to you all.

Speaker 2: Yep. Thank you. Have a great afternoon.