context: Exclusion H does not exclude coverage based on ordinary employee negligence. It excludes coverage only if an employee acts with knowledge of or intent to further a forgery, or intentionally disregards relevant bank policies.
citation_a.signal: cf.
citation_a.parenthetical: refusing to apply Exclusion H where there was no evidence "of employee collusion or of intentional disregard of bank policy"
citation_a.sentence: See Empire Bank, 27 F.3d at 335 (holding loss was “caused” by an employee who ignored bank policies by instructing subordinates to cash corporate checks without proper documentation); cf. Citibank Tex., N.A. v. Progressive Cas. Ins. Co., 2006 WL 3751301, at *6 (N.D.Tex. Dec. 21, 2006) (refusing to apply Exclusion H where there was no evidence “of employee collusion or of intentional disregard of bank policy”), rev’d on other grounds, 522 F.3d 591 (5th Cir.2008).
citation_b.signal: see
citation_b.identifier: 27 F.3d 335, 335
citation_b.parenthetical: holding loss was "caused" by an employee who ignored bank policies by instructing subordinates to cash corporate checks without proper documentation
citation_b.sentence: See Empire Bank, 27 F.3d at 335 (holding loss was “caused” by an employee who ignored bank policies by instructing subordinates to cash corporate checks without proper documentation); cf. Citibank Tex., N.A. v. Progressive Cas. Ins. Co., 2006 WL 3751301, at *6 (N.D.Tex. Dec. 21, 2006) (refusing to apply Exclusion H where there was no evidence “of employee collusion or of intentional disregard of bank policy”), rev’d on other grounds, 522 F.3d 591 (5th Cir.2008).