Spam Alert

Have you been receiving CFPB spam?  Be on the lookout for emails which appear to originate from the CFPB, advising you that a complaint has been lodged against your company and asking you to “click here” or “open an attachment” for more information.


The CFPB has published a notice regarding malicious emails at:

While not a foolproof test (as spammers often hide behind what appear to be valid email addresses), if you “mouse over” the sender’s email address, you may be able to see that it is not from the CFPB — even though the logo, colors and presentation might lead you to conclude that it might be real.  Remember, that next click may lead you to dangerous and damaging malware, spyware, viruses or the like. Read the CFPB notice at the above link for more information.

Richard Kelsky 

How Safe is Your Safe?

By Ric Blum

Just how safe is your safe? Is it made of 21st century, burglary-resistant composite materials? Does it have intricate locking and relocking devices? Does it use digital time locks to prevent unauthorized entry?
The average safe is not that hard to break into. All you need is the right tools, enough time and the ability to avoid detection. When you buy a better safe, you are actually buying more time for detection to occur.
The first thing to accept is if your safe is the burglar’s primary target, this is not going to be your ordinary burglary. Burglars who are targeting safes are going to be well trained and experienced. They will know locks, alarms, the use of the proper tools, your store layout and usually have an idea of the contents of your safe. They will know what kind of safe you have and exactly where it is located. Yes, they might have some inside knowledge of your operation, too.
You won’t have been chosen at random, but will be specifically targeted. A lot of time, effort and planning will have gone into this brazen attack. And you might have been targeted because of your lack of concern over security issues.
How will a burglar enter your store? Too often, business owners concentrate only on the doors.?Criminals know to look at the big picture.

Sneaking In and Watching

Illegal entry should be discreet — that is why rooftop entry is so popular. Often, if the owner or police show because of an alarm, they shake the door, look around and if nothing seems out of order, they leave.
As Jeweler’s Mutual Insurance reports, “Guards or police officers responding to a burglar alarm signal may not be able to detect exterior signs of forced entry and may leave without further investigation. Other times, burglars may trigger an alarm signal and wait to see who responds and how long it takes.”
A professional burglar may attempt to gain entry to your business in steps. First, he gets into an adjacent, unalarmed business. Next, he enters your business from above the ceiling (roof) and prepares to deactivate the alarm system. Your alarm system control box is not located above the drop ceiling, is it? Even if it isn’t, chances are all the wires feed up the wall into the ceiling.
Or a burglar may attempt to access your safe, possibly from the rear, from inside the vacant store to avoid your alarm system altogether.
Many experts say that safes located on an outside wall present the most risk. The risk will quadruple if the outside wall is next to a vacant business. Vacant space could be adjacent, above or below your business.
If a new tenant moves in, make sure they are legitimate. Landlords often overlook things like legitimacy when a store room has been sitting empty for a while.
If you must have your safes on an exterior wall, install alarmed glass panels on rear and sides of the safe to help prevent penetration from an exterior wall and include shock and vibration sensors.

Location, Location, Location

Whether your safe is on display for the public to see or hidden in back is often a matter of your physical layout or convenience.
I have visited many pawnshops where multiple large safes are located right behind the pawn counter where customers may look into them and see all the envelopes full of jewelry. Is this supposed to make your customers feel their jewelry is safe?
It may not be a wise idea to have your safes exposed to everyone who walks in, especially if they are inadequate for protecting your loans or merchandise. This gives the potential burglar first-hand knowledge of what he is up against and the exact location of your safes. In essence, you are doing the burglar’s homework. He now knows exactly what you have and where it is located.
The logic here is the safe is safer because it is in plain sight. Anyone passing by the pawnshop at night can see the safe, including the police (and the bad guys). The visibility from the street adds an additional layer of protection.
Even if you take the hide-it appraoch, no matter how hard you make it, people will always know where your safe is located.
Delivery people, maintenance people, inspectors, repairmen, pest control, HVAC, remodelers, all notice things when they are in your pawnshop and you have no control over who their friends are or with they share what they saw.
Can this information be shared? You bet! Digital cameras are everywhere. Everyone has one. Cellular phones are capable of taking snapshots or recording full length videos. They even sell surveillance-equipped glasses for discreet recording.
Ideally, you should have a large vault or vault room with safes inside. But this is not always practical or affordable.

Replacement Safes

Many of us are thrifty by nature and for cause. We tend to buy local because we can see the product and save money on shipping. At any given time there are a number of adequate safes listed on eBay. But sometimes, a dollar saved is not really a savings.
If your safes are old and outdated, you can find used safes available everywhere. Hey, the economy isn’t that great. Jewelry stores and other businesses are going out of business every day. Check with your safe specialist, who may have taken a trade-in or possibly acquired a used safe from an expired lease or repossession.
Your safe or vault is undoubtedly your final defense against property loss. And, like most things in life, the bigger (stronger), the better. Again, like most things in life, the more protective the safe, the higher the price tag.
Many pawnbrokers are still using the same safe their grandfathers used. I have seen pawnshops where safes were lined up behind the pawn counter against the wall. These are often what I am fond of calling old “rolling record safes” — large, concrete-filled, single or double-door safes on four wheels whose only real protection is armor plate welded to all six sides. This type of safe is easily peeled open with common hand tools.

50 Years of Improvement

While the iron or steel box safe had been the industry standard for more than 100 years, the first real improvement in safe design came in 1962 when Chubb introduced a new production method incorporating TDR (Torch and Drilling Resistance).
This concept was the creation of a seamless bell casting which formed the five-sided protective walls of the safe. Being cast from a proprietary material which deterred cutting and drilling, the safe seemed to be resistant to all the common tools of the day. The door was made of the same material as the safe body.
Safes were now being filled with newly developed, super hard security concrete fillers as an additional effective barrier against forced penetration.
Concretes with fiber fillers and other additives, which were commonly vibrated onto reinforcements securely affixed inside the safe’s shell casting, also hindered attacks by requiring heavier breaching tools, offering longer resistance and often the need to create more noise and smoke, not to mention operator fatigue.

Safecracking 101

Safecracking is any attempt to open a safe with or without the use of the proper combination or key and generally without the safe owner’s consent. While this effort may take two forms, non-destructive and destructive, the latter tends to be most popular.
First and foremost, one must understand that it is not the lock itself that keeps the safe door closed. These locks are merely the ‘key’ to releasing an elaborate mechanical bolt network that secures the safe door from all sides. The hinges on the safe door are not designed to really provide any protection, but merely to keep the door stable and in place.
How to break into a safe is usually a question that only thieves and locksmiths ponder. But anyone owning a business with a safe should have the same thoughts. The more knowledge you have, the more you can protect yourself and your property.
Your safe’s location should be one of your first concerns. Placing your safe against an outside wall may be the most efficient use of space in your building. And you may have fitted your safe with time locks and door alarm contacts. However, depending upon your location’s physical attributes, you may be offering burglars an opportunity to break into your safe without actually setting foot in your store.
If professional burglars are able to gain access to your store all night or weekend because they have compromised your alarm, they could still gain entry to your TRTL-60X6 safe with the proper equipment. The addition of shock or vibration sensors to your safe will be useless if your alarm system is not operational.
A lot of newer safes have security measures in place to prevent some safecracking techniques popular in the past. However, I know many businesses are still relying upon very old and outdated safes and combination locks for security of their goods. So this data is still applicable.
Electronic time delay locks will keep someone from opening the safe in the usual conventional way – by means of the safe door. But our focus here is more unconventional entries, where the person trying to gain entry may be more inclined to use the back or side of the safe for entry and avoid the door altogether.

Non-Destructive Methods

Non-destructive safecracking is based upon overcoming the combination lock and/or key lock by manipulation. Although not necessarily the easiest method of entry, once the locks have been manipulated with the proper sequence of numbers, or the key lock picked, the door will open without any further resistance — the easiest way to gain entry (by opening the safe door, not manipulating the locks).
Almost all safes are shipped from their manufacturer with a preset try-out combination with the intent for the purchaser to pay his local safe mechanic to change the combination.
This doesn’t always happen. Many safe owners continue to use the try-out combination. These try-out combinations are an industry standard and known to all safe vendors, locksmiths and safecrackers (50 – 25 – 50 and 100 – 50 – 100, used to be popular).
Don’t buy an expensive new safe and then be cheap. Have the combination changed.
One method of lock manipulation used by safe mechanics (these are the good guys who work on your safe) and possibly the best safecrackers was devised by Harry C. Miller in 1940. It allows for opening a locked safe without drilling or defacing the safe by using a stethoscope or other electronic listening device.
Miller’s scientific system is a three-step process which manipulates the lock into exposing its combination.
1) Determine the contact points
2) Discover the number of wheels
3) Graph your results
While not as fast as is seen on TV or in the movies, in reality, it is a system that has merit. Sorry, I’m not going to reveal the entire system.
As technology advances, more and more anti-manipulative locks are being marketed. These locks may use wheels made of softer or lightweight materials such as nylon or polycarbonates which may be just as hard and not as telltale as metal wheels.
Auto-dialers, such as the Intralock ITL 2000 Safe Dialer, are computer controlled devices that test the entire set of possible combinations. They mount to the face of the safe and electronically start to dial away. Although this method is very feasible, it may take a considerable amount of time before the safe’s combination lock is breached.
Intralock advertises their ITL 2000 Safe Dialer as having these features:
• Quick and Easy Set up. Only 15 minutes needed
• No supervision required. Once in place, it runs until safe lock opens.
• Average opening time is 6 hours.
• Non-invasive. Safes remain intact and costly repairs are avoided
• 4 dialing speeds for loose wheels
Wheels can be dialed:
• to every possible safe lock combination
• through a specific range of numbers
• Dialer mount attached by strong rare earth magnets
• Reversible jaws grip most dials
While Intralock only sells its Safe Dialer to licensed, bonded and certified security professionals and to law enforcement, things have a way of getting into the hands of the wrong element.
Vibration is a method that was used in the past and may still be applicable on some older combination locks.
This method applies a vibrating mechanism to the combination dial and allows the wheel gates to slowly rotate to the proper “unlock” position. This occurred because of the weight difference between the wheel and the gate.
Modern combination locks alleviate this method by designing wheels that are evenly weighed.
Radiological attack uses a penetrating radiation (beta ray, gamma ray, neutron beam, ultrasound, and x-ray) from a portable device to discretely view the inner workings of a combination lock.
This aligns the wheels in the correct position to engage the lever arm and open the safe door.
Some combination lock wheels are now made of low density materials to prevent this type of attack.
UL Group 1R type combination locks use acetyl resin or other non-metallic wheels to resist x-ray imaging.
Ultra-Violet and Thermal Imaging
Ultra-violet and thermal imaging, which will show UV residue or heat, may be used to indicate which keys or buttons have been used on a safe with an electronic based combination.
While this method may not show the combination, it will narrow down the possibilities by revealing the numbers used most recently.
This method may also be used to detect the numbers entered into your alarms system’s keypad. Can your safe or alarm’s digital keypad be seen or accessed by others? Can I watch you unlock or enter your combination or codes through a telescope or high-powered camcorder’s zoom lens?
Typically, an item the combination owner will come in contact with is coated with a ultra-violet ink.
When the safe combination is initiated, the ink is transferred to the corresponding keys on the electronic keypad. A simple black light can reveal which keys were used.
Thermal Imaging
Thermal imaging is a specialized technology on its own. But when used in conjunction with electronic access controls (electronic safe locks), it can be a quite effective tool.
Technically, the potential safecracker would need to deploy an uncooled micro bolometer thermal imaging (far infrared) camera within five to ten minutes after an electronic key code was entered.
The heat transferred from human contact, even for a split second to the keys, dissipates very slowly, making a reading of the contact possible after the combination owner has left.
The sequence in which the keys were depressed would also be evident by a difference in the color of the keys as they cool, and are visualized or recorded by the thermal image. This image may even be read from a distance of one to ten meters allowing the safecracker to maintain a low profile.
Handheld portable thermal imaging devices and cameras are made by companies like Flir and Fluke and are available to the public — and yes, you can even buy them on

Care Pays Off

In theory, this all works just fine and I’m sure has been used in a movie plot or two. In reality, usually only inside personnel are able to get that close to a safe soon after it has been opened.
Not that an insider might not want unauthorized access or the opportunity to make a few bucks on the side by selling the combination.
There are simple ways to help overcome this method of attack. Use an inanimate object to depress the keys of the electronic combination lock. Hold your hand over the keypad either before or after (or both) to warm all the keys. Use a number twice to make the actual combination harder to detect. Scrambling keypads are also available for high security instances.
Electronic locks are becoming more popular in safes these days and often allow for each individual with access to have their own access code, which then allows for tracking (for security purposes) to determine who was the last one who may have opened a safe. Sophisticated models have a built-in date and time stamps that may record up to the last 200 users and combination entries.
Advances in technology are not usually far behind innovation. J.D. Hamilton of the Mas-Hamilton Group, innovators in electronic locks, has developed a safecracking software that interfaces with electronic locks and will run a sequences of numbers until it finds the proper combination to open an electronic lock. There are reported to be a number of clones of this software on the market.
In these types of scenarios, I see the keypad to your alarm system most susceptible to these threats. Gaining access and deactivating the alarm is step one.
Does your safe or alarm’s electronic keypad have white keys? If so, keep them clean. Dirt from your fingers will eventually build up on the keys and make it easy for anyone to observe which keys are regularly depressed and which are not. n

Editor’s Note: This is Part One of a multi-part series on safes and security.

Ric Blum is a vice president of Ohio Loan Co. in Dayton. He has served as president of the Ohio Pawnbrokers Association, secretary/treasurer of the National Pawnbrokers Association and as a member of the board of directors and the board of governors of the National Pawnbrokers Association. Please feel free to e-mail your comments or tips that you would like to see included in this column to or mail them to Ric Blum, Ohio Loan Co., 3028 Salem Ave., Dayton, OH 45406.

Cordray In Place, Holds Payday Loan Hearing


By Phillip Lee

It certainly didn’t take long. It was ready and waiting. All it needed was someone to lead it. When that became official, it was full steam ahead and off to the races.
The Consumer Financial Protection Bureau was up and running in July of 2011, but without a director. President Barack Obama nominated Richard Cordray to be its director, but the confirmation process went at a snail’s pace. That all changed in the first week of January when Cordray was named CFPB director with a recess appointment.
Cordray’s nomination was a political football as the Senate battled within its ranks to get a confirmation hearing set. Obama had made no secret that he wanted Cordray in place and eventually used the authority of the recess appointment to install him. However, the move has been controversial in terms of whether the president actually has the authority to make this recess appointment.
The move was and was not a surprise to industry officials.
“The idea of a recess appointment has been long discussed as a possibility,” says William Sellery, executive director, Financial Service Centers of America. “With the Republicans working to keep the Senate technically in recess, such an appointment seemed unlikely. For that reason it was unexpected.”
“Not really (surprised),” says D. Lynn DeVault, board chair, Community Financial Services Association of America Community Financial Services Association of America. “The administration had been hinting that there would be a recess appoint so it shouldn’t have come as a surprise to anyone.”

Quick Field Hearing

As soon as Cordray took over the reins, it was apparent non-banks and small loans were at the top of CFPB’s list. Two weeks after his appointment, the CFPB held a field hearing on payday loans in Birmingham.
At the January hearing, Cordray acknowledged the need for “emergency credit,” but also the need to protect consumers.
“One person from Michigan told us of having to use payday loans several times and wanting them to remain available because alternatives did not exist,” Cordray said.
“And so I want to be clear about one thing: We recognize the need for emergency credit. At the same time, it is important that these products actually help consumers, rather than harm them.”
Cordray also announced the Short-Term, Small-Dollar Lending Procedures for the CFPB’s examiners on banks and payday lenders.
“Our examination authority is an important tool that will allow us to inspect their books, ask tough questions, and work with them to fix any problems we uncover,” Cordray said.
“This includes looking at the materials and strategies that are used to market the loans. Before this month, the federal government did not examine payday lenders. Some state regulators have been examining payday lenders for compliance with their state laws. We hope to use our combined resources as effectively as possible.

‘Important New Area’

“So now, the bureau will be giving payday lenders much more attention,” Cordray said. “This is an important new area for us. And the purpose of this field hearing, and the purpose of all our research and analysis and outreach on these issues, is to help us figure out how to determine the right approach to protect consumers and ensure that they have access to a small loan market that is fair, transparent, and competitive.”

Customer Claims Bad Checks Were Loans

By Richard Weatherington

When confronted with multiple returned checks, customers can come up with some interesting claims to try and avoid a conviction for theft-by-check. Recently, a customer claimed that her returned checks were like loans made by the check casher and the check cashing fees she paid were interest for those loans.

A woman, whose first name was Maria, operated a cafeteria, catering, and vending machine business with her three sisters. Between Aug. 8 and 11, 2006, Maria presented 16 company checks she had signed, totaling $93,520, to a Texas check cashing business.
The check casher cashed the checks, which were later returned as “uncollected” or for “insufficient” funds. Although Maria promised the check casher several times that she would pay the checks, she never did.

D.A. Steps In

The check casher contacted the county district attorney’s office, and a fraud investigator in the hot check division, was assigned to the case. After discussions that included her attorney, Maria signed a notarized “Diversion/Partial Payment Program” agreement dated Sept. 25, 2006. The investigator signed the agreement on behalf of the district attorney’s office.
Maria initialed the paragraph in the diversion agreement acknowledging she would not be indicted or prosecuted if she made full restitution by the due date.
Maria paid $3,000 when she signed the agreement in September. She paid another $16,000 in November.
Although she was given several extensions of time until March 2007 to pay the remainder, she made no further payments and was charged with theft-by-check in May 2007.
The evidence at her trial showed that at the time Maria presented the checks to the check casher in August 2006, he had been cashing her business checks since late 2004.
Between December 2005 and Aug. 6, 2006, the check casher cashed more than 1,000 checks totaling approximately $4.4 million and for which he charged total check cashing fees of approximately $88,000.
The check casher testified he was comfortable cashing the larger checks after physically visiting one of Maria’s job sites and observing the nature of the business.
Maria claimed that her business arrangement with the check casher was like a loan because he would cash her checks knowing there were insufficient funds in the company’s bank account. Maria said he would hold the checks for a day until she could deposit money from other sources to cover the checks.
She claimed the check casher’s check cashing fee was interest for these loans and that this arrangement was necessary because she had a “cash flow problem.”

Claims No Debt

The check casher testified he normally deposited checks the evening of receipt or the next day; he denied having an agreement with Maria to hold her checks for one day. He also testified he believed she had the funds in her account to cover the checks when he cashed them.
The trial court questioned him about why Maria went to him instead of the bank. The court said it sounded like she was short of money, noting that she would put a $10,000 catering job check in the bank, and tell the check casher that she couldn’t wait till it cleared, because she needed the money right then.
The check casher said that was the case most of the time for business customers. The court asked if that was kind of a typical transaction, and he said it was.
Maria claimed she had “no intent of stealing any money.” She told the court that the August 2006 checks bounced because checks from one of her suppliers “started returning,” which caused her bank to “freeze” her account. She also said her checks would not clear because her account balance fell too low when the supplier’s checks bounced.
Maria presented evidence that showed the supplier’s checks were being returned as early as July 2006. She also testified that she “had no problem until they froze the account” and that her checks to the check casher would have cleared “had they not froze the account.” The only evidence, however, that Maria’s account was frozen came from her own testimony.
The state presented evidence that Maria’s account was overdrawn in the amount of approximately $48,000 on Aug. 17, 2006.
Maria claimed the bank “unfroze” her account after two months with a balance remaining of $16,167.33. Her July 2006 bank statement showed deposits being made almost every day through the last day of the month2006. The August 2006 bank statement showed no deposits after the 14th. The September 2006 bank statement showed no activity on the account.
The investigator, who at the time of trial had been the fraud, hot check division supervisor for approximately four years, testified no one presented him with or described any loan agreement or arrangement as had been claimed by Maria. He said he saw nothing that caused him to believe the situation presented anything other than a theft by check case.

Convicted of Theft

Maria was convicted for theft by check in an aggregated amount of at least $20,000 but less than $100,000. The trial court sentenced her to two years in prison, suspended the sentence, placed Maria on 10 years’ community supervision, and ordered her to pay $109,147 in restitution.
Maria appealed her conviction to the Texas Court of Appeals, claiming first that the evidence was legally insufficient to show she had the intent to commit theft at the time she wrote the checks and, second, that the trial court should not have admitted the pre indictment diversion agreement, which she claimed was inadmissible.

Sufficiency of the Evidence

On appeal, Maria first claimed that the evidence was insufficient to support her conviction because the state failed to prove beyond a reasonable doubt that she “had the intent to commit theft at the time she wrote the checks.”
In determining whether the evidence is sufficient to support a conviction, the Appeals Court said it must view all of the evidence in the light most favorable to the verdict and determine whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. The standard recognizes that the trier of fact is the sole judge of the credibility of the witnesses and the weight to be given their testimony.
A person commits the offense of theft if he “unlawfully appropriates property with intent to deprive the owner of property.” As to each check here, said the Appeals Court, the indictment alleged that Maria unlawfully appropriated the check casher’s property (currency) with intent to deprive him, and without the effective consent of the check casher, namely, by issuing and passing a check, when Maria did not have sufficient funds in the bank for the payment in full of the checks.
The issue was whether the evidence supported a finding beyond a reasonable doubt that she unlawfully appropriated the check casher’s property. Appropriation of property is unlawful if, as alleged in this case, it was without the owner’s effective consent.
The Appeals Court noted that the check casher consented to Maria’s appropriation of his property — he cashed her checks. But this consent was not “effective” if it was induced by “deception.”

Definition of Deception

“Deception” is basically defined in the theft provisions of the penal code as failing to correct a false impression of law or fact that is likely to affect the judgment of another in the transaction, that the person previously created or confirmed by words or conduct, and that the person does not now believe to be true.
Measured against this legal standard of “deception,”, said the Appeals Court, a rational trier of fact could have found beyond a reasonable doubt that Maria unlawfully appropriated the check casher’s property.
She knew she had cash flow problems. She not only admitted, but insisted, that she had the check casher cash checks for her at a time when there were insufficient funds in her bank account.
She also knew her checks would not clear when checks from the supplier “started returning.” Those checks were being returned in July 2006.
Maria’s bank records showed the account was overdrawn by approximately $48,000 on Aug. 17, 2006, within a week of the August 11 checks the check casher cashed for her. The checks to him were returned as “uncollected” or for “insufficient” funds, and Maria failed to pay him back despite repeated promises to do so.
The check casher testified he deposited Maria’s checks the day of receipt or the next day and he believed she had funds to cover the checks. The fraud investigator testified based on his experience that he saw nothing in his investigation that caused him to believe the situation presented anything other than a theft by check case.

Cites Evidence

The Appeals Court said that the trial court was the sole judge of the credibility of the witnesses. From this evidence, the trial court could have concluded beyond a reasonable doubt that Maria obtained the funds from the check casher by failing to correct a false impression she had previously created that the funds would be in her account at least by the next day; the impression likely affected the check casher’s judgment, and Maria did not believe that impression to be true.
Maria argued that the key issue in this case was whether deception existed at the time the checks were written, and whether the state proved that on the date she wrote the checks, there were insufficient funds in her account to cover them.
She claimed the evidence was clear that on the dates the checks were written, she had no reason to believe the funds were not in her account, and she therefore did not have the intent to commit theft.

Recent Case

The Appeals Court noted that in 2011, the Texas Court of Criminal Appeals decided in the case of Geick v. State that “if an indictment uses a statutory definition to specify how a theft was committed, the state must prove the offense as charged in the indictment.”
In that case, the court held the state was required to produce evidence of “deception” because the state unnecessarily pleaded that the theft was by deception but provided no proof of deception; the evidence therefore was legally insufficient to support the conviction.
The indictment in Maria’s case, said the Appeals Court, alleged that with each check, that she unlawfully appropriated the check casher’s property with intent to deprive him, and without his effective consent, namely, by issuing and passing a check when she did not have sufficient funds in and on deposit with the bank for the payment in full of the checks.
This allegation, unlike the allegation of “deception” in the Geick case, was not a statutory element or definition of a theft offense that narrowed the manner and means under which Maria could have been convicted of theft.
Therefore, this allegation didn’t, for sufficiency purposes, exclude theft by deception as a manner and means in which the offense could have been committed.

Allegation Supported

The Appeals Court noted that even assuming the state was required to produce evidence to support the allegation of insufficient funds, the evidence supported the allegation.
Maria’s August 2006 bank statement showed she wrote three checks totaling $18,025 on Aug. 8, 2006, with her daily balance on that date being $7,116.31.
The bank statement also showed Maria wrote three checks totaling $15,525 on Aug. 9, 2006, with her daily balance on that date of $928.07. This was some evidence that Maria knew she had insufficient funds in her bank to cover these checks when she wrote them.
The aggregated amount of these checks exceeded $20,000 and was less than $100,000, which was the range alleged in the indictment. This evidence, and evidence the checks were returned as “uncollected” or for “insufficient” funds, supported the indictment allegation that Maria passed the checks when she “did not have sufficient funds in and on deposit with the bank for the payment in full of the checks.”