8th Circuit Distinguishes "Intraday Overdrafts" from "True Overdrafts" In Determ
In Saracheck v. Luna Savings Bank, the chapter 7 trustee sought to recover deposits made by corporate debtor AgriProcessors, Inc. to its bank account to cover overdrafts in the 90 day preference period. The bank's policy was to provisionally settle all checks and debit the account. When the provisional settlement caused or contributed to a negative account balance, an "intraday overdraft" occurred. Under Iowa law, the provisional settlement did not become final until