have concluded that the bank customer’s failure to prompdy discover and report a forgery or unauthorized transaction after it has occurred may also constitute negligence under U.C.C. § 3-406, even though such negligence does not directly contribute to the making of a forgery or an alteration. The rationale generally appears to be that such failure to report contributes to the making of subsequent forgeries. See, e.g., Fundacion Museo de Arte Contemporaneo de Caracas — Sofia Imber v. CBI-TDB Union Bancaire Privee, 996 F. Supp. 277 (S.D. N.Y. 1998) (noting that customer’s negligence in maintaining and controlling blank checks along with failure to advise bank of the first forgery substantially contributed to the loss); Kramer v. Chase Manhattan Bank, N.A., 653 N.Y.S.2d 546 (1997) (<HOLDING>); Gulf States Section, PGA, Inc. v. Whitney
holding as a general rule that a bank and its customers do not have a special or confidential relationship holding that a bank should not be held responsible for losses caused by a customers failure to safeguard his or her atm card and pin and to timely examine statements holding that bank customers whose personal information was stolen from a company that had been retained by the bank did not suffer any present injury or reasonably certain future injury holding that the national bank act preempts state regulation of the posting order of debit card transactions as well as any obligation to make specific affirmative disclosures to bank customers holding that bank had right to set off funds in a customers account against debt that the bank customer had incurred as a surety or guarantor