Thank you for the response. I am trying to figure out if we might have liablity to the estate beneficiaries or creditors if an ACH from a joint account that was only authorized by the deceased joint tenant is allowed to go out the door. Maybe where there are rights of survivorship it is less of a concern, but even then, what if the surviving joint tenant did not want the money to go out?
1.Seems like best practice might be to systematically freeze all debit entries that we initiate until we talk with the surviving joint tenant.
2. Debit entries initiated by another bank - we have no way to know which client authorized the entry, so if we are on notice of the death of one of them, it seems like they should be returned with an R15 code. Or, are we still protected by the warranty by the ODFI even though we have notice of death?
3.Credit entries we initiate - I think we have to stop them if we are debiting an outside account owned by the decedent or any account if the authorization only came from the decedent. Allow if suriving client authorizes.
4.Credit entries initiated by another bank. Not at all sure what to do. I think we have to return if it was a benefits payment to the decedent. Otherwise, maybe accept the payment but restrict the funds until an executor is appointed?
Would you do anything differently if the account did not have rights of survivorship?
I appreciate thoughts anyone has on this. Perhaps we're making this too complicated, but we are trying to write automated rules and manage our risk, but not unecessarily inconvenience clients.