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#2233928 - 03/30/20 07:16 PM COVID-19 STIMULUS CHECKS
ComplianceGurl, CRCM Offline
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I am wondering how other FI's will be handling the forthcoming COVID-19 stimulus checks if the deposit account it is directed to is no longer open? Due to the need some people will have for this check I am hesitant to instantly return without doing a little bit of research. Maybe the individual has a different deposit account at the FI that we could reroute it to? Or maybe we could place the funds in a designated GL account and issue them a cashiers check for the deposited amount? Both of these options we would require customer/individual approval but would need to act quickly within 24 hours.
Thoughts?
Thank you!

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Deposits and Payments
#2233932 - 03/30/20 07:47 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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#2233990 - 03/31/20 05:11 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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Thank you rlcarey!

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#2234164 - 04/02/20 08:46 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
Ms. X Offline
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rlcarey, might you be able to excerpt the info from that link? I get the following message - Sorry, you are not logged in or you don't have permission for that. Thank you!

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#2234167 - 04/02/20 08:53 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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Basically it comes down to this:

I don't think that it is something that the bank wants to step into the middle of. How in the world would they ever track down their money if you can't locate them?? If the ACH is returned, they will mail them a check.

Or in other words - you have the staff and time to do this sort of research on every rejected ACH deposit within 24 hours at this time with all that is going on?
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#2234169 - 04/02/20 09:06 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
Ms. X Offline
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Thank you!

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#2234731 - 04/13/20 11:56 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
Angela Offline
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What if a stimulus check comes into an account and the names don't match? Our system does not automatically match names from the ACH to the account. We do not manually match names either. Will we be required to for these transactions?

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#2234733 - 04/14/20 11:36 AM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
terpsfan Offline
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Are there any restrictions on these funds covering the overdrawn balance in the account it is deposited into?

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#2234734 - 04/14/20 11:39 AM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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ACH requires you to credit the account to which it was sent. While some banks match names, there is no requirement to do so.

There is no prohibition on using the funds to bring a currently overdrawn account into the positive.
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#2234735 - 04/14/20 12:14 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
HappyGilmore Offline
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Pulling people out of the ditc...
you should use the US Treasury Green Book for guidance, here is what they state for misdirected payments:

Quote
Notice of Misdirected Payment In accordance with 31 CFR part 210, if an RDFI becomes aware that an agency has originated an ACH credit entry to an account that is not owned by the payee whose name appears in the ACH payment information, the RDFI shall promptly notify the agency. An RDFI that originates a NOC entry with the correct account and/or RTN information or returns the original ACH credit entry to the agency with the appropriate return reason code, shall be deemed to have satisfied this requirement.
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#2234744 - 04/14/20 01:30 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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"becomes aware" is the key phrase in that section. Becoming aware is not the same as a requirement to search for the occurrence.
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#2234758 - 04/14/20 03:50 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
jbowman Offline
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Just curious to how other banks are going to handle ACH stimulus payments after a recent divorce...

For example, husband and wife have a joint account and have bank information set up with the IRS to automatically be deposited via ACH. Fast forward a few months and the couple is no longer together and divorced. Husband opens up a new account owned solely by him. The wife keeps the joint account as her own sole account and removes husbands name.

The way I understand it, the bank is not technically required to match the name and account number. The bank has the requirement to ensure it has a valid account number only. I don't think this is something we want to start returning since the account is still open and not closed. Any thoughts? Just trying to get a plan in place because I'm sure scenarios like this will come up.

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#2234760 - 04/14/20 03:58 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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That is one reason why you never remove the name from an account if the other party is still living.
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#2234764 - 04/14/20 04:17 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
jbowman Offline
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Yep, I understand and totally agree with you. I'm just guessing somewhere along the line a CSR maybe tried to take a shot cut. Always room for more training. Thanks!

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#2234777 - 04/14/20 06:34 PM Re: COVID-19 STIMULUS CHECKS rlcarey
kmenard Offline
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Can the stimulus checks be used to bring a past due loan current or are the funds protected? I see this as a reputation risk and nightmare but management would like to do this. Thanks for any help.

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#2234778 - 04/14/20 06:41 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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There is no mention that these funds are protected. Huge reputational risk however.
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#2234779 - 04/14/20 06:45 PM Re: COVID-19 STIMULUS CHECKS rlcarey
kmenard Offline
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That is what I said...why risk any negative news during this time.

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#2234782 - 04/14/20 06:52 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
rlcarey Online
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https://soundcloud.com/theamericanprospect

Listen to the audio of Rhonda Kent - you can start around 3:25 in the recording.
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#2234785 - 04/14/20 07:02 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
BrianC Offline
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#2234837 - 04/15/20 02:50 PM Re: COVID-19 STIMULUS CHECKS Angela
John Burnett Offline
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Originally Posted by Angela
What if a stimulus check comes into an account and the names don't match? Our system does not automatically match names from the ACH to the account. We do not manually match names either. Will we be required to for these transactions?

No, you aren't required to pore over the ACH files trying to match up names with the names on the designated account records. In this situation, "ignorance is bliss." Treasury regulations require that when you become AWARE of a mismatch, you need to return the payment. So, be careful handling the rejects (and there will be rejects).
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#2234851 - 04/15/20 04:17 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
dottiec Offline
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Do we return a stimulus check that come in for a deceased person?
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#2234852 - 04/15/20 04:24 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
BrianC Offline
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Illinois
Since the law says that estates are not included in the stimulus payments, I would.
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#2234854 - 04/15/20 04:36 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
dottiec Offline
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What if only one party is deceased?

For example, Account was joint (Husband and wife) $2400 is received, but husband is deceased.

We can't return half of the ACH.
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#2234855 - 04/15/20 04:39 PM Re: COVID-19 STIMULUS CHECKS ComplianceGurl, CRCM
reknab Offline
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not where I want to be
we are returning on closed or incorrect accounts. does anyone know how long it will take for govt to issue a check once they receive the return?

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#2234859 - 04/15/20 04:58 PM Re: COVID-19 STIMULUS CHECKS reknab
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted by reknab
we are returning on closed or incorrect accounts. does anyone know how long it will take for govt to issue a check once they receive the return?


they will begin printing and mailing checks May 5, estimate to mail 5 million a week until all mailed...I have heard expect mailings to go as long as 20 weeks. so no way to determine when they would get. Best case is they sign on to IRS website and update top provide a valid account, and it will get redone via ACH
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