Citibank, which is currently appealing from a District Court ruling against it in a $900 million payment error case, has got backing from Robert L. Clarke, a former United States Comptroller of the Currency.
Mr Clarke has submitted an Amicus Curiae (that is, a Friend to the Court) letter at the Second Circuit Court of Appeals. He advises that the judgment against Citi should be reversed.
The case concerns wire transfers made on August 11, 2020 in relation to Revlon’s 2016 Loan.
Let’s recall that, in 2016, Revlon acquired Elizabeth Arden, Inc. The deal was partially facilitated by a seven-year, $1.8-billion loan. Brigade currently holds a portion of the loan. The Credit Agreement governs the term loans held by Brigade. Citibank serves as the administrative agent and collateral agent for the loan.
On August 11, 2020, several months of accrued interest came due under a credit agreement. The interest payment was to be processed by Citibank in its capacity as administrative agent. No other amount was due at the time, and Revlon transferred no additional funds to Citibank.
The interest payment was processed by Citibank on August 11, 2020. Due to issues with the loan-processing system, the payment to each lender was on average more than 100 times the interest that was actually due. Brigade was one of the lenders that received an overpayment.
This operational mistake caused Citibank to transfer approximately $900 million of its own money to parties that were not entitled to it. When Citibank discovered the mistake, it promptly asked the recipients to return its money. Some recipients did return the money, but some did not.
Citi tried to recover the funds it allegedly sent by mistake but the District Court ruled against the bank, stating that the payments Citibank made on August 11, 2020, were final. Put otherwise, the firms that got the money Citibank sent will not have to return it.
Now, Citi has the backing of Robert L. Clarke.
In the letter to the Court, Mr Clarke notes that the likelihood of errant wire transfers should not be underestimated.
He says that, for banks, both in the United States and overseas, it is a challenge to establish and maintain completely foolproof internal controls. This is not entirely surprising, given the complexity and volume of these institutions’ operations. Even the most highly developed control systems are not (and cannot be expected to be) perfect, Mr Clarke explains.
He then enlists a set of examples of errant transfers from recent years.
In March 2018, for instance, Deutsche Bank transferred $35 billion to an exchange in error, the apparent result of an employee accidentally selecting euros instead of yuan as the transfer currency. The mistake occurred though the bank had installed a supposedly “fail-safe” system after a 2014 errant transfer of $24.62 billion that was reportedly a result of “human error.”
Similarly, in 2017, Germany’s state-owned development bank KfW mistakenly transferred more than $5.4 billion to four separate entities because of a glitch that repeated single payments multiple times, and a bank in China mistakenly transferred 1.2 billion yuan to a new customer because an employee mistook his 10-digit account number for a transfer amount.
Mr Clarke notes that none of these errors is meaningfully different in an operational sense from the one committed by the Citibank contractors involved in this case. The biggest difference is that, in each of these other examples, the bank quickly recovered all of its mistakenly transferred money.
As long as human involvement is required, mistakes will occur. And it is highly unlikely this will be the last such mistake, Mr Clarke says, adding that because the circumstances under which the mistaken transfer occurred are not unique, as the District Court ruled, affirming that ruling would introduce a serious risk of additional unfair results for years to come.
Robert L. Clarke is an attorney with decades of experience in the field of bank regulation and supervision. Mr Clarke served as United States Comptroller of the Currency from December 1985 through February 1992, leading the Office of the Comptroller of the Currency (OCC).
Mr Clarke also served as a Director of the Federal Deposit Insurance Corporation (1985-1992) and the Resolution Trust Corporation (1989-1992), and as Chair of the Federal Financial Institutions Examination Council (1989-1991).
He also served as a consultant to the World Bank and as senior adviser to the President of the National Bank of Poland. From 2004 until December 31, 2015, Mr. Clarke served as a member of the board of directors of the Dubai Financial Services Authority, overseeing operations of financial services providers licensed and operating in the Dubai International Financial Centre. Mr. Clarke has also served on the Boards of public companies, including service as a director of Eagle Materials Inc., Mutual of Omaha Insurance Company, and Stewart Information Services Corporation.
He is a graduate of Rice University and Harvard Law School.
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Your passion and dedication to your craft radiate through every article. Your positive energy is infectious, and it’s evident that you genuinely care about your readers’ experience. Your blog brightens my day!
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Your storytelling prowess is nothing short of extraordinary. Reading this article felt like embarking on an adventure of its own. The vivid descriptions and engaging narrative transported me, and I eagerly await to see where your next story takes us. Thank you for sharing your experiences in such a captivating manner.
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Your storytelling prowess is nothing short of extraordinary. Reading this article felt like embarking on an adventure of its own. The vivid descriptions and engaging narrative transported me, and I eagerly await to see where your next story takes us. Thank you for sharing your experiences in such a captivating manner.
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Your dedication to sharing knowledge is unmistakable, and your writing style is captivating. Your articles are a pleasure to read, and I consistently come away feeling enriched. Thank you for being a dependable source of inspiration and information.
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Your passion and dedication to your craft radiate through every article. Your positive energy is infectious, and it’s evident that you genuinely care about your readers’ experience. Your blog brightens my day!
In a world where trustworthy information is more crucial than ever, your dedication to research and the provision of reliable content is truly commendable. Your commitment to accuracy and transparency shines through in every post. Thank you for being a beacon of reliability in the online realm.
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In a world where trustworthy information is more crucial than ever, your dedication to research and the provision of reliable content is truly commendable. Your commitment to accuracy and transparency shines through in every post. Thank you for being a beacon of reliability in the online realm.
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Your positivity and enthusiasm are undeniably contagious! This article brightened my day and left me feeling inspired. Thank you for sharing your uplifting message and spreading positivity among your readers.
Your dedication to sharing knowledge is unmistakable, and your writing style is captivating. Your articles are a pleasure to read, and I consistently come away feeling enriched. Thank you for being a dependable source of inspiration and information.
Your blog is a true gem in the vast expanse of the online world. Your consistent delivery of high-quality content is truly commendable. Thank you for consistently going above and beyond in providing valuable insights. Keep up the fantastic work!
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This article resonated with me on a personal level. Your ability to emotionally connect with your audience is truly commendable. Your words are not only informative but also heartwarming. Thank you for sharing your insights.
I’ve discovered a treasure trove of knowledge in your blog. Your unwavering dedication to offering trustworthy information is truly commendable. Each visit leaves me more enlightened, and I deeply appreciate your consistent reliability.
Your blog has rapidly become my trusted source of inspiration and knowledge. I genuinely appreciate the effort you invest in crafting each article. Your dedication to delivering high-quality content is apparent, and I eagerly await every new post.
Your positivity and enthusiasm are undeniably contagious! This article brightened my day and left me feeling inspired. Thank you for sharing your uplifting message and spreading positivity among your readers.
I’m truly impressed by the way you effortlessly distill intricate concepts into easily digestible information. Your writing style not only imparts knowledge but also engages the reader, making the learning experience both enjoyable and memorable. Your passion for sharing your expertise is unmistakable, and for that, I am deeply grateful.
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I wanted to take a moment to express my gratitude for the wealth of invaluable information you consistently provide in your articles. Your blog has become my go-to resource, and I consistently emerge with new knowledge and fresh perspectives. I’m eagerly looking forward to continuing my learning journey through your future posts.
Your blog is a true gem in the vast online world. Your consistent delivery of high-quality content is admirable. Thank you for always going above and beyond in providing valuable insights. Keep up the fantastic work!
Your passion and dedication to your craft radiate through every article. Your positive energy is infectious, and it’s evident that you genuinely care about your readers’ experience. Your blog brightens my day!
Your storytelling prowess is nothing short of extraordinary. Reading this article felt like embarking on an adventure of its own. The vivid descriptions and engaging narrative transported me, and I eagerly await to see where your next story takes us. Thank you for sharing your experiences in such a captivating manner.
I’m truly impressed by the way you effortlessly distill intricate concepts into easily digestible information. Your writing style not only imparts knowledge but also engages the reader, making the learning experience both enjoyable and memorable. Your passion for sharing your expertise is unmistakable, and for that, I am deeply grateful.
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I wanted to take a moment to express my gratitude for the wealth of valuable information you provide in your articles. Your blog has become a go-to resource for me, and I always come away with new knowledge and fresh perspectives. I’m excited to continue learning from your future posts.
Your positivity and enthusiasm are truly infectious! This article brightened my day and left me feeling inspired. Thank you for sharing your uplifting message and spreading positivity to your readers.
I simply wanted to convey how much I’ve gleaned from this article. Your meticulous research and clear explanations make the information accessible to all readers. It’s abundantly clear that you’re committed to providing valuable content.
Your storytelling prowess is nothing short of extraordinary. Reading this article felt like embarking on an adventure of its own. The vivid descriptions and engaging narrative transported me, and I eagerly await to see where your next story takes us. Thank you for sharing your experiences in such a captivating manner.
This article is a true game-changer! Your practical tips and well-thought-out suggestions hold incredible value. I’m eagerly anticipating implementing them. Thank you not only for sharing your expertise but also for making it accessible and easy to apply.
I must applaud your talent for simplifying complex topics. Your ability to convey intricate ideas in such a relatable manner is admirable. You’ve made learning enjoyable and accessible for many, and I deeply appreciate that.
Your enthusiasm for the subject matter shines through every word of this article; it’s infectious! Your commitment to delivering valuable insights is greatly valued, and I eagerly anticipate more of your captivating content. Keep up the exceptional work!
I’ve discovered a treasure trove of knowledge in your blog. Your unwavering dedication to offering trustworthy information is truly commendable. Each visit leaves me more enlightened, and I deeply appreciate your consistent reliability.
Your storytelling abilities are nothing short of incredible. Reading this article felt like embarking on an adventure of its own. The vivid descriptions and engaging narrative transported me, and I can’t wait to see where your next story takes us. Thank you for sharing your experiences in such a captivating way.
This article resonated with me on a personal level. Your ability to emotionally connect with your audience is truly commendable. Your words are not only informative but also heartwarming. Thank you for sharing your insights.
I’ve discovered a treasure trove of knowledge in your blog. Your unwavering dedication to offering trustworthy information is truly commendable. Each visit leaves me more enlightened, and I deeply appreciate your consistent reliability.
In a world where trustworthy information is more crucial than ever, your dedication to research and the provision of reliable content is truly commendable. Your commitment to accuracy and transparency shines through in every post. Thank you for being a beacon of reliability in the online realm.
This article is a true game-changer! Your practical tips and well-thought-out suggestions hold incredible value. I’m eagerly anticipating implementing them. Thank you not only for sharing your expertise but also for making it accessible and easy to apply.
This article is a true game-changer! Your practical tips and well-thought-out suggestions hold incredible value. I’m eagerly anticipating implementing them. Thank you not only for sharing your expertise but also for making it accessible and easy to apply.
I am continually impressed by your ability to delve into subjects with grace and clarity. Your articles are both informative and enjoyable to read, a rare combination. Your blog is a valuable resource, and I am sincerely grateful for it.
This article resonated with me on a personal level. Your ability to emotionally connect with your audience is truly commendable. Your words are not only informative but also heartwarming. Thank you for sharing your insights.
Your storytelling prowess is nothing short of extraordinary. Reading this article felt like embarking on an adventure of its own. The vivid descriptions and engaging narrative transported me, and I eagerly await to see where your next story takes us. Thank you for sharing your experiences in such a captivating manner.
Your blog is a true gem in the vast online world. Your consistent delivery of high-quality content is admirable. Thank you for always going above and beyond in providing valuable insights. Keep up the fantastic work!
Your passion and dedication to your craft radiate through every article. Your positive energy is infectious, and it’s evident that you genuinely care about your readers’ experience. Your blog brightens my day!
This article is a real game-changer! Your practical tips and well-thought-out suggestions are incredibly valuable. I can’t wait to put them into action. Thank you for not only sharing your expertise but also making it accessible and easy to implement.
I wanted to take a moment to express my gratitude for the wealth of invaluable information you consistently provide in your articles. Your blog has become my go-to resource, and I consistently emerge with new knowledge and fresh perspectives. I’m eagerly looking forward to continuing my learning journey through your future posts.
In a world where trustworthy information is more crucial than ever, your dedication to research and the provision of reliable content is truly commendable. Your commitment to accuracy and transparency shines through in every post. Thank you for being a beacon of reliability in the online realm.
Your positivity and enthusiasm are undeniably contagious! This article brightened my day and left me feeling inspired. Thank you for sharing your uplifting message and spreading positivity among your readers.
I must applaud your talent for simplifying complex topics. Your ability to convey intricate ideas in such a relatable manner is admirable. You’ve made learning enjoyable and accessible for many, and I deeply appreciate that.
Your positivity and enthusiasm are truly infectious! This article brightened my day and left me feeling inspired. Thank you for sharing your uplifting message and spreading positivity to your readers.
I must applaud your talent for simplifying complex topics. Your ability to convey intricate ideas in such a relatable manner is admirable. You’ve made learning enjoyable and accessible for many, and I deeply appreciate that.
I wish to express my deep gratitude for this enlightening article. Your distinct perspective and meticulously researched content bring fresh depth to the subject matter. It’s evident that you’ve invested a significant amount of thought into this, and your ability to convey complex ideas in such a clear and understandable manner is truly praiseworthy. Thank you for generously sharing your knowledge and making the learning process so enjoyable.
Your dedication to sharing knowledge is unmistakable, and your writing style is captivating. Your articles are a pleasure to read, and I consistently come away feeling enriched. Thank you for being a dependable source of inspiration and information.
I’m genuinely impressed by how effortlessly you distill intricate concepts into easily digestible information. Your writing style not only imparts knowledge but also engages the reader, making the learning experience both enjoyable and memorable. Your passion for sharing your expertise is unmistakable, and for that, I am deeply appreciative.
Your writing style effortlessly draws me in, and I find it difficult to stop reading until I reach the end of your articles. Your ability to make complex subjects engaging is a true gift. Thank you for sharing your expertise!
I’ve discovered a treasure trove of knowledge in your blog. Your unwavering dedication to offering trustworthy information is truly commendable. Each visit leaves me more enlightened, and I deeply appreciate your consistent reliability.
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I must commend your talent for simplifying complex topics. Your ability to convey intricate ideas in such a relatable way is admirable. You’ve made learning enjoyable and accessible for many, and I appreciate that.
Your positivity and enthusiasm are truly infectious! This article brightened my day and left me feeling inspired. Thank you for sharing your uplifting message and spreading positivity to your readers.
I’ve discovered a treasure trove of knowledge in your blog. Your unwavering dedication to offering trustworthy information is truly commendable. Each visit leaves me more enlightened, and I deeply appreciate your consistent reliability.
I wanted to take a moment to express my gratitude for the wealth of invaluable information you consistently provide in your articles. Your blog has become my go-to resource, and I consistently emerge with new knowledge and fresh perspectives. I’m eagerly looking forward to continuing my learning journey through your future posts.
In a world where trustworthy information is more crucial than ever, your dedication to research and the provision of reliable content is truly commendable. Your commitment to accuracy and transparency shines through in every post. Thank you for being a beacon of reliability in the online realm.