Known as the Early Journal Content, this set of works include research articles, news, letters, and other writings published in more than 200 of the oldest leading academic journals. The works date from the mid--seventeenth to the early twentieth centuries. We encourage people to read and share the Early Journal Content openly and to tell others that this resource exists. People may post this content online or redistribute in any way for non--commercial purposes. Read more about Early Journal

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... ntent at http://about.jstor.org/participate--jstor/individuals/early-journal--content. JSTOR is a digital library of academic journals, books, and primary source objects. JSTOR helps people discover, use, and build upon a wide range of content through a powerful research and teaching platform, and preserves this content for future generations. JSTOR is part of ITHAKA, a not--for--profit organization that also includes Ithaka S+R and Portico. For more information about JSTOR, please contact support@jstor.org. was a result: the payment to C, and was willing, as a business proposition, to take the credit of the bank, and secondly, because of the difficulty of proper treatment, by the banks concerned, of the claim against correspondent banks if it is to be regarded as a trust res. Are they to hold each claim in trust as a separate account until the money is actually received by O? Perhaps the court in the principal case might be said to be bound by its previous special deposit cases?1 to follow the American rule, were it not for the fact that in a comparatively recent case, in a situation which is strictly congruous, if not, indeed, legally identical, it was held by the same court that there is a marked distinction between issuing a draft, traveller's check or "cable transfer" and receiving money for actual transmission, and that the seller of a cable transfer sells a credit for a sum of money, payable at a place indicated in the contract." And a still more controlling basis for departure should be the nature of the exchange business itself.12 If the relation set up is a fiduciary one, then the money deposited must be held as a separate fund until credit is secured from a correspondent bank, which bank will, in turn, be compelled to treat the claim as a trust claim and may not set off debits against it. The first operation would certainly be contrary to the whole basis of the banking business which depends upon the use of the money deposited with it; while as to the latter, the practical consideration of how to carry and adjust the claims between banks until the contract is performed and the credit paid at the foreign point is of much greater force, because the fact that there is a continuous transfer of enormous sums makes it impracticable to finance such operations as individual transactions without balancing accounts. Because it overlooks general business practices and the intentions of business men in such transactions, the rule in the principal case is unfair to an existing economic situation, and, it is submitted, should be modified so as to be more in line with modern conditions. R. L. W. THE DOCTRINE OF PURCHASE FOR VALUE AS APPLIED TO THE TRANS- FER OF EQUITABLE INTERESTS.-In the recent case of Casner v. Schwartz (1918) 198 Mo. App. 237, 201 S. W. 592,1 A executed and delivered to B two duplicate notes, each of which was for the entire amount of a loan made by B to A, and secured them by a conveyance to X, trustee. 1o People ex rel. Zotti v. Flynn (1909) 135 App. Div. 276, 120 N. Y. Supp. 511; 10 Columbia Law Rev. 358. I1 Strohmeyer & Arpe v. Guaranty Trust Co. (1916) 172 App. Div. 16, 157 N. Y. Supp. 955. 12 In the dissenting opinion of the principal case, 173 N. Y. Supp. 814, Shearn, J., at p. 819: ". . . foreign exchange or credit is a subject of purchase and sale, and not only may be, but is commonly, contracted for in the same manner and governed by the same laws as in the case of purchase of wheat, cotton, or any other subject of commerce." 1The statement of facts is somewhat simplified.