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4671 A bank does not owe a non-customer a duty of reasonable care to investigate or otherwise prevent a thief from forging the non-customer's name, opening accounts, depositing checks payable to the non-customer, and stealing the proceeds; the fact that a thief fraudulently opened a bank account in the name of a victim does not make the victim a customer of the bank.CitationRODRIGUEZ v BANK OF THE WEST (Bank's Duty) 162 CA4 454 [See: CA-UCC 4104; Chazen v Centennial Bank 61 CA4 532, T/AT 3/98; Software Design v Hoefer 49 CA4 472, T/AT 10/96]
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