Does a husband owe a duty of loyalty to his wife?

While the husband did owe a duty of loyalty, he apparently did not owe a duty of care. "As one note writer has observed: 'Evidently a husband is free to make unwise purchases, to speculate freely in stocks and securities or to use personal property foolishly without the wife's consent, for in these situations the desirability of freely transferable personal property is thought to outweigh the harm suffered by the wife.' [Citation.]" (Bank of California v. Connolly (1973) 36 Cal.App.3d 350, 377-378.) To extend the duty further, another commentator stated, would "'hamper the exercise of his [husband's] business initiative, prejudice the rights of those who deal with him, and generally hinder commercial transactions.'" (Id. at p. 378.)