Our institution just aquired another institution and I've found this account that I'm concerned in relation to the activity and the documentation. I'm hoping others have some background on this that you can assist me with.
We have a general partnership business account that has multiple ACH direct deposits from the US Treasury for income tax refunds to multiple individuals. This customer does income tax returns, however is not a CPA, (I realize that's not a redquirement). The only documentation they supplied to the bank was a hold harmless agreement for the direct deposits that they have thier clients sign. Is allowing these refunds to be deposited into a business account from a tax preparer legal? If so, what type of documentation to support that it's legal can we get?
What ongoing monitoring is the bank required to perform? If there are not checks to offset the direct deposits to these individuals, this is a concern to me as well.
I would appreaciate any input.