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#2198647 - 11/19/18 05:09 PM Deceased Customer and Use of Card after Death
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 543
Auditing this account and wondering if we could have handled it differently?
Customer is sole owner of DDA w/ bank, he dies 5/20/18
customer receives SSA deposit on 5/23/18
customer receives VA benefit payment deposit on 6/1/18
Bank is notified of death 6/5/18 via ACH DNE
Beginning on 5/22 through 6/4/18 there are card transactions that post on customer's account, obviously not done by the deceased customer, as transactions list a date/time and most are POS purchases with or without PIN. Bank discovers customer's daughter has been using his card.
Bank is required to return SSA and VA payments/deposits, so account then becomes overdrawn.
Is bank out the money for the card transactions that occurred after the sole owner's death? Or is there something more that could have/should have been done in this situation? Thanks.

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Deposits and Payments
#2198649 - 11/19/18 05:19 PM Re: Deceased Customer and Use of Card after Death TeamComply
TeamComply Offline
Platinum Poster
Joined: Aug 2016
Posts: 543
Correction: Bank was only required to return VA benefit deposit, not the SSA benefit deposit. Regardless, the account still went OD as a result of card use after the sole owner's death.

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#2198651 - 11/19/18 05:24 PM Re: Deceased Customer and Use of Card after Death TeamComply
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
You'll most likely receive a reclamation for the SSI deposit at some point.

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#2198656 - 11/19/18 05:42 PM Re: Deceased Customer and Use of Card after Death TeamComply
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
Originally Posted By TeamComply
Or is there something more that could have/should have been done in this situation? Thanks.


Notify the daughter that she needs to make the bank whole or you will be prosecuting her for fraud.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2198772 - 11/20/18 04:58 PM Re: Deceased Customer and Use of Card after Death TeamComply
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
1. Under Treasury Fiscal Service regulations (and the Green Book), once you have learned of a customer's death, you are supposed to return any ACH recurring federal payment received for the customer's account after you gain that knowledge, including any SSA payment that you know the decedent qualified for by surviving through the end of the prior month. Customer dies November 4, bank learns of death on November 6, SSA ACH arrives November 9, it gets returned R15. Customer dies November 4, SSA payment arrives November 9, bank learns of death November 12, bank does not have to return the 11/12 credit (but can't accept any more ACH Treasury payments for SSA or VA, etc.

2. On learning of the death, the card should have been shut down.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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