We recently received a Notice of Reclamation from the goverment for our customer who passed away in November 2010. I did some research and found guidance from 2011 which said something to the extent that RDFI could protest the reclamation due to the time contraints on receiving the notice. I believe it said 120 days after the agency constructively learns of the death. I'm taking the stance that they stopped sending the checks the following month so they knew he had passed. Am I correct in my line of thinking? I think we're certainly going to take a shot at the protest. Comments?
I don't think you can assume they knew. For all you know someone pretending to be the deceased may have switched the bank the benefits were going to. It may be worth your time to go back to your reports from the month following the last payment to see if they sent you a DNE (Death Notice).
Valid point. I hadn't considered that possibility. Yes, the green book! That's what I was reading. Thank you for the feedback, I'll certainly go check for a DNE.