Estate of Freitag v. Frontier Bank

Cox, A.C.J.

The rights and duties of parties relating to “payment orders”1 are governed by Article 4A of the Uniform Commercial Code (“Funds Transfers”), not Article 3 (“Negotiable Instruments”). The primary issue in this case is whether Frontier Bank (Bank) or the estate of its deceased customer, Eugene Freitag (Estate), should bear the loss arising from certain payment orders to the Bank that Estate contends were not authorized. Patricia Olson, *225the original personal representative of the estate (PR), made the payment orders, and later absconded with the funds that were the subjects of these…