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
Bankers' Threads User #8