The US District Court for the Northern District of Texas, Dallas Division has ruled that the insurers for a property management software company are not obligated to compensate the company for money lost in a phishing scheme after the company failed to technically hold that the funds were stolen. The case is RealPage Inc. v. National Union Fire Insurance Co. of Pittsburgh, PA and Beazley Insurance Co., Inc. 2021 U.S. Dist. LEXIS 341116.

RealPage is a company that provides services for property owners and managers such as collecting rent and other payments from residents and transferring those payments to its clients. The payments are made through a third-party payment processor, Stripe Inc., and held in Stripe's bank account before being passed on to the clients.

RealPage had a commercial crime policy through AIG's National Union Fire INsurance. The policy provided $5 million in coverage subject to a $50,000 deductible and covered property owned or held by the policyholder. RealPage also had an excess fidelity and crime policy through Beazley that had a $5 million liability limit.