When you first described it as "cashing checks off the account," I was concerned you were referring to checks payable to the beneficiary by third parties, and the beneficiary cashing them based on some confused idea that if one of them bounced, you could charge it back to the Rep Payee account. THAT would be a non-starter, since you would not have the right to recover against the account.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8