Expert Report of Charles H. Grice — Blue Flame Medical LLC v. Chain Bridge Bank, N.A., et al., No. 1:20-cv-00658

Source document: Expert Report Of Charles H. Grice; document type: Expert report (wire-transfer industry standards/UCC Article 4A).

Full text

EXHIBIT 91

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CONFIDENTIAL

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

BLUE FLAME MEDICAL LLC,

Plaintiff,
v.

CHAIN BRIDGE BANK, N.A.,
JOHN J. BROUGH, and
DAVID M. EVINGER,

Defendants.
Civil Action No. 1:20-cv-00658

EXPERT REPORT OF CHARLES H. GRICE
February 12, 2021
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TABLE OF CONTENTS
I.

BACKGROUND AND ASSIGNMENT ............................................................................ 1
II.
COMMUNICATIONS AND FEDWIRE MESSAGES BETWEEN
JPMORGAN AND CHAIN BRIDGE DEMONSTRATE THAT JPMORGAN
REQUESTED, AND CHAIN BRIDGE AGREED TO, A STANDARD WIRE
TRANSFER CANCELLATION ........................................................................................ 2
III.
UNDER INDUSTRY PRACTICE AND CUSTOM FOR APPLYING THE
U.C.C., JPMORGAN’S CANCELLATION REQUEST RENDERED IT
LIABLE FOR ANY LOSSES AND EXPENSES THAT CHAIN BRIDGE
INCURS AS A RESULT OF THE CANCELLATION ..................................................... 9

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I.
BACKGROUND AND ASSIGNMENT
1.
I have been retained by Robbins, Russell, Englert, Orseck, Untereiner & Sauber
LLP, on behalf of Defendant/Third-Party Plaintiff Chain Bridge Bank, N.A. (“Chain Bridge”), and
Defendants John J. Brough, and David M. Evinger, in connection with the case captioned Blue
Flame Medical LLC v. Chain Bridge Bank, N.A., John J. Brough, and David M. Evinger, No. 1:20-
cv-00658 (E.D.V.A.).
2.
Plaintiff Blue Flame Medical LLC (“Blue Flame Medical”) brings claims related
to a wire transfer of $456,888,600 originated on March 26, 2020 by the State of California (“the
California Wire Transfer”), through its bank, JPMorgan Chase Bank, N.A. (“JPMorgan”), to Chain
Bridge for the benefit of Blue Flame Medical, and that wire’s subsequent return the same day.1
Defendant Chain Bridge brings third-party claims against JPMorgan for indemnification under
Uniform Commercial Code (“U.C.C.”) § 4A-211(f) and for other equitable relief.
3.
I have been asked to apply my expertise in industry standards and practices
concerning wire transfers and recalls to assess whether JPMorgan’s request that Chain Bridge
return the California Wire Transfer was, under the surrounding circumstances, a “cancellation” as
bankers in this industry understand and apply that term found in U.C.C. § 4A-211(f), thus
triggering JPMorgan’s liability to Chain Bridge for any losses or expenses that Chain Bridge incurs
as a result of the cancellation. As explained below, I conclude that JPMorgan’s request that Chain
Bridge return the California Wire Transfer was a “cancellation.”
4.
All opinions expressed in this report are my own. I am not an attorney and offer no
legal opinions. In preparing this report, I relied upon my education, experience, and knowledge of

1
Complaint, Blue Flame Medical, LLC v. Chain Bridge Bank, N.A., John J. Brough, and David Evinger, Civil Action
No. 20 Civ. 00658, filed June 12, 2020, ¶¶ 1-3 and 61.
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industry standards and practices relating to funds transfers; documents produced in discovery and
deposition testimony; and publicly-available data and documents. I am being compensated at a
rate of $850 per hour for my independent review and analysis provided in this case. This
compensation is not contingent on the nature of my findings or the outcome of this litigation.
5.
For the sake of convenience and efficiency, I incorporate by reference into this
report the “Qualifications” and “Background” sections of my separate report served in this matter
also dated February 12, 2021, as well as Appendices A, B, and C to that report.
II.
COMMUNICATIONS AND FEDWIRE MESSAGES BETWEEN JPMORGAN
AND CHAIN BRIDGE DEMONSTRATE THAT JPMORGAN REQUESTED, AND
CHAIN
BRIDGE
AGREED
TO,
A
STANDARD
WIRE
TRANSFER
CANCELLATION
6.
The incoming California Wire Transfer arrived at Chain Bridge Bank via Fedwire
at 11:55 a.m. on March 26.2 That Fedwire message identified the sending bank as JPMORGAN
CHASE, and the receiving bank as CHAIN BRIDGE BK. The amount stated was $456,888,600.
Fedwire messages generally include a Type/Subtype Code corresponding to the nature of the
message. This Fedwire’s Type/Subtype was “1000,” reflecting type code “10” (a funds transfer)
and subtype code “00” (a basic value transfer).3 The Fedwire message also had unique Input
Message Accountability Data (IMAD) and Output Message Accountability Data (OMAD)
numbers.4

2
Fedwire Funds Processor Message, March 26, 2020 at 11:55 a.m., CBB00002779.
3
Fedwire, Fedwire Funds Service, Format Reference Guide, p. 14 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
4
Fedwire, Fedwire Funds Service, Format Reference Guide, pp. 1, 13 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
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7.
In Section IV.D.3 of my separate report served in this matter today, I discuss Chain
Bridge’s communications with Rakesh Korpal and Tim Coffey of JPMorgan following receipt of
the California Wire Transfer. On the first of those calls, at 12:31 p.m., Mr. Coffey told Chain
Bridge that JPMorgan had “concerns of fraud.”5 A little over ten minutes later, at 12:44 p.m., Mr.
Korpal informed Mr. Brough and Mr. Evinger that JPMorgan’s “Global Security Investigation
Team is coming back to me and saying that this does not look right either.”6 Following those
communications, on a subsequent call at or around 1:35 p.m., Mr. Evinger of Chain Bridge asked
Mr. Korpal if there was “any way for JPMorgan to issue a recall for the wire, so that while you
intervene in this you have the funds and feel more comfortable.”7 Mr. Korpal replied that “I feel
comfortable that you are holding the money right now.”8 Mr. Korpal further acknowledged that he
“can issue a recall,” however, and asked Chain Bridge for “a few more minutes.”9
8.
In my experience, communication among financial institutions involved in a
potentially suspicious wire transfer is commonplace. Because a wire transfer’s sending bank is the
institution that would issue any cancellation request, Mr. Evinger’s question to Mr. Korpal about
to the possibility of a wire recall reflects customary discussion among a receiving and sending
bank preceding a cancellation request.
9.
Minutes later, Mr. Coffey of JPMorgan called Mr. Brough and Mr. Evinger of
Chain Bridge again.10 Mr. Coffey stated: “We’re going to be recalling those funds, okay? We have

5
Call between Mariano Castagnello and Tim Coffey, March 26, 2020, 12:31 p m. ET, CBB00002784; see Deposition
of Timothy Coffey (Rough), February 11, 2021, p.63:12 - 21.
6
Call between David Evinger, John Brough and Rakesh Korpal, March 26, 2020, 12:44 p.m. ET, CBB00002541-542.
7
Call between David Evinger, John Brough and Rakesh Korpal, March 26, 2020, 1:35 p.m. ET, CBB00002544.
8
Call between David Evinger, John Brough and Rakesh Korpal, March 26, 2020, 1:35 p.m. ET, CBB00002544.
9
Call between David Evinger, John Brough and Rakesh Korpal, March 26, 2020, 1:35 p.m. ET, CBB00002544.
10  Call between David Evinger, John Brough and Tim Coffey, March 26, 2020, 1:37 p.m. ET, CBB00002545.
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enough concerns that we feel like we need to claw those funds back.”11 Based on my experience,
Mr. Coffey’s statement is correctly interpreted as a request by JPMorgan to cancel the California
Wire Transfer.  Mr. Coffey’s statements that JPMorgan had decided to “recall[] those funds” and
“claw those funds back” used words and phrases that, when associated with wire transfers, are
synonymous with the word “cancel” in standard industry practice. Mr. Coffey’s stated reason for
JPMorgan’s cancellation request was that “we feel like we need to claw those funds back.”12
10.
Mr. Coffey asked Mr. Brough and Mr. Evinger whether Chain Bridge “needed a
recall message from us.”13 A recall message refers to a Fedwire service message that
communicates a sending bank’s wire-cancellation request to a receiving bank. Mr. Evinger replied
to Mr. Coffey that Chain Bridge did, in fact, want an “official communication from JPMorgan to
us to recall the funds.”14 Asking for written documentation of a sending bank’s cancellation request
is customary industry practice. Mr. Brough’s testimony that a service message across Fedwire
provides “proper documentation that [a] wire [i]s being recalled” is consistent with my
understanding and experience that a recall message is good practice among banks that handle wire
cancellations and amendments.15
11.
At 2:05 p.m., JPMorgan sent Chain Bridge a Fedwire Funds Processor message.16
That Fedwire message’s Type/Subtype was “1001,” reflecting type code “10” (a funds transfer)

11  Call between David Evinger, John Brough and Tim Coffey, March 26, 2020, 1:37 p.m. ET, CBB00002545.
12  Call between David Evinger, John Brough and Tim Coffey, March 26, 2020, 1:37 p.m. ET, CBB00002545.
13  Call between David Evinger, John Brough and Tim Coffey, March 26, 2020, 1:37 p.m. ET, CBB00002545.
14  Call between David Evinger, John Brough and Tim Coffey, March 26, 2020, 1:37 p.m. ET, CBB00002545.
15  Deposition of John Brough, February 2, 2021, p. 297:8 - 9.
16  Fedwire Funds Processor Message, March 26, 2020 at 2:05 p m., CBB00002780.
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and subtype code “01” (request for reversal).17 As described by Fedwire’s guidance for the
formatting of messages on its platform, subtype code “01” is what a bank uses to convey “A non-
value request for reversal of a funds transfer originated on the current business day.”18 In addition,
JPMorgan’s Fedwire message asked Chain Bridge to “PLS RETURN FUNDS QUOTING OUR
REF,” and provided a unique reference number for JPMorgan under “Additional Information.”19
12.
JPMorgan’s 2:05 p.m. Fedwire service message also included a “Previous Message
Identifier” corresponding to the IMAD unique identifier of the 11:55 a.m. payment message, and
stated the amount of the cancelled wire, $456,888,600.20 It is customary practice, and consistent
with Fedwire message-formatting guidance, for a wire-cancellation request to refer to the unique
identifier and amount of the wire transfer that is being cancelled. In my opinion, JPMorgan’s 2:05
p.m. Fedwire message is consistent with industry practice and message-formatting guidance for a
standard wire cancellation request.
13.
At 3:21 p.m., Chain Bridge honored JPMorgan’s cancellation request by a Fedwire
payment message.21 That Fedwire message’s Type/Subtype was “1002,” reflecting type code “10”
(a funds transfer) and subtype code “02” (reversal of transfer).22 As described by Fedwire’s
guidance for the formatting of messages on its platform, subtype “02” is what a bank uses to

17  Fedwire, Fedwire Funds Service, Format Reference Guide, p. 14 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
18  Fedwire, Fedwire Funds Service, Format Reference Guide, p. 14 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
19  Fedwire Funds Processor Message, March 26, 2020 at 2:05 p m., CBB00002780.
20  Fedwire Funds Processor Message, March 26, 2020 at 2:05 p m., CBB00002780; see Fedwire Funds Processor
Message, March 26, 2020 at 11:55 a m., CBB00002779.
21  Fedwire Funds Processor Message, March 26, 2020 at 3:21 p m., CBB00002781.
22  Fedwire, Fedwire Funds Service, Format Reference Guide, p. 14 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
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convey “A value reversal of a funds transfer received on the current business day.”23 Fedwire’s
message-formatting guidance continues that message subtype “02” “[m]ay be used in response to
a subtype code ‘01’ Request for Reversal.”24 Accordingly, and pursuant to industry practice and
Fedwire guidance, a wire transfer’s receiving bank would assign subtype code “02” to a Fedwire
message in response to a cancellation request from the wire transfer’s sending bank to
communicate the same-day reversal of the wire transfer.
14.
Chain Bridge’s 3:21 p.m. Fedwire message also included a “Previous Message
Identifier” corresponding to the IMAD unique identifier of the 11:55 a.m. payment message, and
stated the amount of the cancelled wire, $456,888,600.25 It is customary practice, and consistent
with Fedwire message-formatting guidance, for a wire reversal to refer to the unique identifier and
amount of the wire transfer that is being cancelled.
15.
Finally, Chain Bridge’s 3:21 p.m. Fedwire message populated the “F[inancial]
I[nstitution (“FI”)] to FI Information” section with the text “RTNG YR IMAD” “PER YOUR
REQUEST.”26 I understand “RTNG YR” to be shorthand in Fedwire messaging for “returning
your.” The “FI to FI Information” section again included the IMAD unique identifier of the 11:55
a.m. payment message, along with the reference number that JPMorgan’s 2:05 p.m. Fedwire

23  Fedwire, Fedwire Funds Service, Format Reference Guide, p. 14 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
24  Fedwire, Fedwire Funds Service, Format Reference Guide, p. 14 (November 19, 2011), available at
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.445.7645&rep=rep1&type=pdf, accessed February 10,
2021.
25  Fedwire Funds Processor Message, March 26, 2020 at 3:21 p m., CBB00002781; see Fedwire Funds Processor
Message, March 26, 2020 at 11:55 a m., CBB00002779.
26  Fedwire Funds Processor Message, March 26, 2020 at 3:21 p m., CBB00002781.
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message had requested be used in connection with the wire reversal.27 This additional language
and identification from Chain Bridge in response to JPMorgan’s stated instructions is consistent
with my understanding that this was a wire transfer cancellation undertaken at JPMorgan’s request.
16.
In sum, I have reviewed Chain Bridge’s communications with JPMorgan following
receipt of the California Wire Transfer over the Fedwire system at 11:55 a.m., as well as
JPMorgan’s 2:05 p.m. request-for-reversal Fedwire service message and Chain Bridge’s 3:21 p.m.
reversal-of-transfer Fedwire message. In my opinion, based on my more than 30 years working
with financial institutions involved in funds transfers, compliance, supervisory exams, and
operational challenges, JPMorgan’s oral request to “recall” and “claw back” the California Wire
Transfer and its request-for-reversal Fedwire message, along with Chain Bridge’s responses to the
same, constitute a standard wire-transfer cancellation request and an agreement to that request in
accordance with industry standards.
17.
In my experience, and consistent with customary industry practice, the question
that Mr. Evinger posed to Mr. Korpal on their 1:35 p.m. call, about whether there was any way for
JPMorgan to recall the wire while JPMorgan was intervening in the transaction, reflects a typical
question that a receiving bank might pose to a sending bank about how the sending bank intends
to handle, or wishes to proceed in handling, a potentially suspicious funds transfer originated by a
customer of the sending bank amidst any accompanying investigation. In this industry, receiving
banks asking such questions do not understand such inquiries to affect the nature of any
cancellation request they ultimately receive from the sending bank, nor to undermine the sending
bank’s indemnification obligations associated with such cancellation requests. Based on my

27  Compare Fedwire Funds Processor Message, March 26, 2020 at 3:21 p.m., CBB00002781, with Fedwire Funds
Processor Message, March 26, 2020 at 2:05 p m., CBB00002780, and Fedwire Funds Processor Message, March 26,
2020 at 11:55 a m., CBB00002779.
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experience, it is my opinion that it would chill and undermine financial institutions’ willingness to
cooperate in the due diligence of potentially suspicious funds transfers if their discussions
preceding a potential cancellation request might be understood to change receiving banks’ and
sending banks’ industry-standard rights and obligations in connection with such a cancellation
request. The resulting confusion and uncertainty surrounding a sending bank’s indemnification
obligations would redound to the detriment of the safety and soundness of the banking system.
18.
I have considered JPMorgan’s testimony, provided through Mr. Korpal, that
JPMorgan recalled the wire only because of Mr. Evinger’s request from Chain Bridge to recall the
funds.28 Putting to one side what actually motivated JPMorgan’s decision to recall the wire,
conversations such as the ones between Mr. Evinger and Mr. Korpal prior to JPMorgan’s recall
are the norm. According to industry practice and understanding, nothing about the substance and
nature of such discussions has a bearing on the sending bank’s obligations, post-recall, under
Regulation J and U.C.C. Article 4A. Consistent with Regulation J and U.C.C. Article 4A, a sending
bank has the discretion whether to issue a wire cancellation request, and cannot be compelled to
do so by a receiving bank. And a receiving bank likewise cannot agree to a cancellation request
unless the sending bank makes one. Mr. Coffey’s oral cancellation request, JPMorgan’s Fedwire
service message cancelling the wire, and Chain Bridge’s responsive Fedwire message and payment
are all consistent with customary industry practice for a JPMorgan-initiated and requested wire
cancellation.

28  See Deposition of Rakesh Korpal, February 9, 2021, p. 79:16 - 19.
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III.
UNDER INDUSTRY PRACTICE AND CUSTOM FOR APPLYING THE U.C.C.,
JPMORGAN’S CANCELLATION REQUEST RENDERED IT LIABLE FOR ANY
LOSSES AND EXPENSES THAT CHAIN BRIDGE INCURS AS A RESULT OF
THE CANCELLATION
19.
JPMorgan (as the California Wire Transfer’s sending bank) and Chain Bridge (as
the California Wire Transfer’s receiving bank) are subject to the provisions of the U.C.C. for
sending and receiving wire transfers through the Fedwire system, including U.C.C. § 4A-211(f).
In my experience, receiving banks that honor sending banks’ requests to return a wire transfer do
so based on the understanding that Section 4A-211(f) provides for the sending bank to indemnify
the receiving bank that, “after accepting a payment order, agrees to cancellation or amendment of
the order by the sender . . . whether or not cancellation or amendment is effective.” That
indemnification provision covers “any loss and expenses, including reasonable attorney’s fees,
incurred by the [receiving] bank as a result of the cancellation.”  Id.
20.
Based on my experience in the industry, receiving banks that participate in the
Fedwire system have the discretion to agree to sending banks’ requests to cancel accepted funds
transfers. As online banking has become an increasingly important part of the banking business,
sophisticated Internet-enabled fraud, identity theft, money-laundering schemes, and other
suspicious activity have made wire recalls and cancellations more commonplace in the industry.
21.
Recalls and cancellations come with risk for receiving banks, especially after
having accepted an incoming wire transfer (which effectively occurs automatically by operation
of the Fedwire system). A receiving bank’s post-acceptance return of a cancelled wire to a sending
bank may result in, among other things, a beneficiary’s challenge to the effectiveness of the
cancellation or other circumstances associated with the receiving bank’s return of the cancelled
wire. In my experience, receiving banks therefore generally understand and rely on Section 4A-
211(f) of the U.C.C. to protect them from any losses when they agree to comply with sending
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banks’ cancellation (i.e., recall) requests. In particular, receiving banks generally rely on this
provision and understand that it causes a  sending bank that makes a cancellation request to bear
the risk that its cancellation will be deemed ineffective, lead to expensive litigation, or otherwise
result in costs or expenses to the receiving bank. Absent such a safeguard, receiving banks would
rarely, if ever, honor requests to cancel wire transfers that they have already accepted.
22.
When a sending bank wishes to opt out of the U.C.C.’s indemnification obligation
in connection with a wire-transfer cancellation request, it is industry practice that it do so explicitly
and in writing prior to the receiving bank’s decision to comply with a cancellation request.
Specifically, a sending bank intending to opt out of the standard indemnification requirements will
include the clear phrase “NO INDEMNITY,” or similar phrasing, in the text of a Fedwire request
to return a wire. Doing so provides a receiving bank with clear notice that it, rather than the sending
bank, will bear any risk of loss associated with the sending bank’s cancellation request should it
choose to accept that request. This practice is consistent with paragraph 14.1 of the Federal Reserve
Banks Operating Circular No. 6: Funds Transfers Through the Fedwire Funds Service, which was
in effect on March 26, 2020 and which states that “[b]y requesting cancellation or amendment of
a Payment Order, the sender may be liable under Section 4A-211 of Article 4A unless the request
states ‘NO INDEMNITY.’”29 All else equal, a “no indemnity” qualifier on a wire-transfer
cancellation request makes it more likely that a receiving bank will not agree to honor the
cancellation.
23.
I am unaware of any “No Indemnity” or similar disclaimer made by JPMorgan in
connection with its request to cancel the California Wire Transfer. In particular, no such disclaimer

29  Federal Reserve Banks Operating Circular No. 6, FUNDS TRANSFERS THROUGH THE FEDWIRE FUNDS
SERVICE ¶¶ 1.1, 14.1 (December 20, 2019), available at https://www.frbservices.org/assets/resources/rules-
regulations/122019-operating-circular-6.pdf, accessed February 5, 2021.
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is found in JPMorgan’s 2:05 p.m. Fedwire service message, which is where I would expect to see
any such disclaimer under customary industry practice and the then-operative version of the
Federal Reserve Banks Operating Circular No. 6.30 It is therefore my opinion, based on my years
of experience and knowledge of industry practice, that Chain Bridge’s agreement to JPMorgan’s
cancellation request, whether or not that cancellation was effective, triggered JPMorgan’s liability
to Chain Bridge for any losses and expenses, including reasonable attorney’s fees, incurred by
Chain Bridge as a result of the cancellation.

Submitted on February 12, 2021

________________________
Charles H. Grice

30  Fedwire Funds Processor Message, March 26, 2020 at 2:05 p m., CBB00002780; Federal Reserve Banks Operating
Circular No. 6, FUNDS TRANSFERS THROUGH THE FEDWIRE FUNDS SERVICE ¶14.1 (December 20,
2019), available at https://www.frbservices.org/assets/resources/rules-regulations/122019-operating-circular-6.pdf,
accessed February 5, 2021.
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