In Van de Kamp v. Bank of America (1988) 204 Cal. App. 3d 819, the court affirmed a summary judgment in favor of the bank defendant, concluding that it had breached no fiduciary duty in the manner it held and disbursed certain of plaintiffs' funds. The court explained that while the bank may act as plaintiffs' agent for some purposes, with concomitant fiduciary duties, that agency relationship was not plenary: "The bank's duty as agent is limited to the scope of the agency set forth in the parties' agreement. . . .Thus, the scope of the agency extends only to the collection of cash proceeds; after that, the agency ends and a debtor and creditor relationship commences and defendant is allowed to use and profit from the cash proceeds." (Id. at pp. 860-861.)