Does the RDFI NACHA guidelines apply with the stimulus? For ex - customer A receives stimulus for his friend, "B" who is not on the account. If the treasury determines this was sent in error, does the Treasury have the 5 days to request return or not? Who suffers the loss if the funds are gone?

You would process an ACH in this format? I think we reject an ACH when the originator (An individual) is different than the beneficiary (An individual).

In alignment with the processing of Federal tax refunds, if a financial institution posts an Entry based on the information in the Entry without touching it, by posting it to the exact account number in the Entry, it will face no liability.

Many banks however will not post ACHs with a name mismatch and will return them. But they are under no obligation to do so.

Our Deposit Operations group also sent out an e-mail to the front line last week. If we receive a stimulus deposit to two individuals and the account is only in one name it will be returned.

Good to know. Thanks Randy.

Does your bank also return an IRS tax refund ACH with two names when it's aimed at a single owner account? The IRS gives people a lot of flexibility on where they send their ACH refunds. If H and W each have individually-owned accounts, they can have half of the joint refund go to each. The ACH will show both names (because they filed jointly) but the accounts aren't joint. Then the IRS uses one of those accounts to send the EIP ACH. Do you really want to make things difficult for your depositors who might be in desperate need of the funds?

At the end of the day, it is your bank's decision, of course.

https://www.irs.gov/refunds/frequently-asked-questions-about-splitting-federal-income-tax-refunds

If I want to split my refund among different accounts, can those accounts be with different financial institutions?

You can split your refund among up to three different U.S. financial institutions as long as they will accept a direct deposit to your account.

Remember: You can ask IRS to direct deposit your refund into your account, your spouse’s account or a joint account. But you should verify that your financial institution accepts a joint refund into an individual account.

Yes, and I do credit the IRS for including that caveat about checking with the bank first.

John B - they only check with the bank AFTER the entry was returned, never before setting it up, you know that.

Yes. It's not unlike assembling furniture from Ikea before looking at the instruction sheet.