What is the burden of a first bank on a check cashing company?

In fact, our decision articulates no more of a burden even on first banks than they already have. That burden is a light one: (a) It only affects first banks which have check cashing companies as customers, and even then it only applies (b) to those checks presented by check cashing companies to their own banks which are made out to a business or corporation. Those checks appear to represent a tiny percentage of something less than 4 percent of check cashing companies' total business.²² And even as to that tiny percentage, check cashers and their banks can protect themselves by the simple expedient of the check casher obtaining a written authorization from any business or corporation to whom a check is payable that the business or corporation has authorized a given individual to sign checks on its behalf. (See, e.g., Kuhn v. Tumminelli (2004) 366 N.J.Super. 431, 443444, 841 A.2d 496 [discussing level of documentation which might establish business's

[231 Cal.App.4th 240]