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#1333097 - 01/28/10 06:29 PM Reopen a Closed Deposit Account?
Anonymous
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Our bank is looking into the possibility of reopening closed consumer deposit accounts (closed due to an overdraft charge-off), when being notified by our ACH area that a direct deposit came in for a closed account. Is there any regulation or ACH rule that I should look into that would prohibit us from doing this?

Our bank closes an account after 45 days of being overdrawn. At which time there would be a 15 day window after closing the account were a direct deposit can come in. By reopening the account our collections area would recover the charged off portion. The bank would then notify the customer via mail with details of the direct deposit amount that came in, the Bank's recovery efforts, and how the accountholder can get the remaining funds as the account has certain privileges restricted.

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#1335422 - 02/02/10 01:42 AM Re: Reopen a Closed Deposit Account? Anonymous
buggs Offline
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Joined: May 2005
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I can't say about regulations or NACHA, but before you even go there, you should take a look at your deposit agreement and see if it addresses this first.

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#1337243 - 02/04/10 01:37 PM Re: Reopen a Closed Deposit Account? buggs
Anonymous
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This might be more of a legal issue than a compliance. Recommend legal to review for any other issues.

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#1337983 - 02/04/10 09:57 PM Re: Reopen a Closed Deposit Account? Anonymous
buggs Offline
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Which triggers the question, "How do you determine whether an issue is "legal" vs. "compliance?"

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#1338102 - 02/04/10 11:52 PM Re: Reopen a Closed Deposit Account? buggs
rlcarey Offline
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Galveston, TX
It is a very fine line, but when it comes down to interpreting the law, it is best left to the lawyers - anything else is personal opinion - such as found in these threads.
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#1339607 - 02/08/10 07:16 PM Re: Reopen a Closed Deposit Account? rlcarey
Always In Training Offline
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Where the Green Grass Grows
Plus, if it's a government entitlement check there are stipulations as to whether or not you can "collect" your funds from one of these ACH credits. You absolutely can not offset your fees or C/O ODs with certain direct deposits. These we return, "account closed" and inconvience the former depositor rather than take it, call them, tell them, "Your rail-road retirement check came in on your closed OD checking account and we accepted it, so, please come pick up your cashier's check for the money..."

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