Law.com has this article about a recent decision by the Supreme Court of South Carolina on a certified question from the D.S.C., in which the Court held that banks could not be liable for negligence in issuing credit cards to impostors.
The question certified was this: "Does South Carolina law recognize the tort of Negligent Enablement of Impostor Fraud? If so, what are the elements of the tort and does plaintiff's complaint state an actionable claim for the tort?" Man, that's a weird question. Negligence in negligence. I would have guessed the question was more like, do banks have a duty to exercise reasonable care to prevent impostors from causing harm to others by obtaining credit cards in their names - or something like that.
The Court ruled on the basis that the connection between the credit card issuers and the consumers is too attenuated.