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#1517878 - 03/04/11 07:36 PM HSAs Overdrafts and Reg E
BTO Offline
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Joined: Feb 2011
Posts: 4
I have a couple of questions involving HSAs.
First in terms of the new Reg E Changes how are HSAs to be treated. I think they should be Exempt but can they also be Opted-In?
Also, we have checking accounts that act as a "suspense" accounts for our HSA accounts when they are accessed by check or debit card. We have had a situation recently where that HSA checking account was overdrafted. Can we charge OD and NSF fees to this checking account or is that still considered part of the HSA?

Thanks!

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#1517886 - 03/04/11 07:42 PM Re: HSAs Overdrafts and Reg E BTO
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
The payment of any overdraft on an HSA account is a prohibited transaction.

How you collect and charge for any overdrafts would be outside of the HSA account and would most likely have to be covered by your account agreements.
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#1518247 - 03/07/11 04:53 PM Re: HSAs Overdrafts and Reg E rlcarey
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Joined: Feb 2011
Posts: 4
What if the Account that is Overdraft is the Checking Suspense Account and not the actual HSA, do the same rules apply?

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#1518518 - 03/08/11 12:12 AM Re: HSAs Overdrafts and Reg E BTO
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
I have never heard of a Checking Suspense Account attached to an HSA so I can't answer your question. Sounds like you may have a cobbled together program if you have to run transactions through multiple accounts to post transactions. Do your agreements cover this process? What is the base account? A savings account? If so and you are eventually posting checks and debit card transactions to the savings account by running them first through a shadow checking account, you most likely are going to run afoul of the Reg. D savings account transaction limitations.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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