Tax Refunds after Date of Death
04/07/2019
We recently learned that our customer died. We’ve returned the SSA payments that have posted to the account. Do we return the Tax Refund too?
Rayleen M. Pirnie
Bio:
Rayleen M. Pirnie, AAP, CERP, is the founder and owner of RP Payments Risk Consulting Services, LLC. based in Missouri. She is a nationally recognized payments risk and fraud expert who offers specialized consulting services, procedural and risk management reviews, and payments education. Rayleen’s specialized skill is delving into the world beyond the payment rules; areas where organizations often find themselves in positions of liability or loss with little to no clear guidance. Her programs help organizations identify and mitigate risk and exposure.
She is an Accredited ACH Professional (AAP) and a Certified Enterprise Risk Professional (CERP) who has worked with all payment systems for over 20 years. Rayleen also holds a Bachelor of Science in Criminal Justice Administration.
Questions Answered
SSI Payments to Deceased Customer
03/31/2019
Family members of one of our customers came in to let us know our customer (sole-owner account) passed away; we now have a copy of the death certificate. The day after this happened, an SSI payment came into the account. Do we wait for the Government to reclaim the payment or should we return it?
Insurance company demand for reimbursement
03/24/2019
We just learned our customer is deceased; he passed 4 months ago. It’s a sole-owner account. The account has a small balance, but we’ve been contacted by an insurance company saying that we have to return the last 3 payments because payments should have ceased when the customer died. Returning these will overdraw the account, and we likely will have to return funds for SSI payments too. Do we have to comply with the insurance company?
Benefits payment to closed account
03/17/2019
Our customer closed their sole-owner account last week; he has another account with us, but it’s a joint account. Today we received a VA benefits payment to the old account. Should we put the funds into the other account?
Returns in the ACH Network
03/10/2019
Does the ACH Rules cover every type of situation where a customer wants to return an entry?
Alive and well, but reported deceased
03/10/2019
We received a Notice of Reclamation for a customer who we know for certain is actually still alive. The reclamation is for $1,800. What do we do?
ACH Rules vs. Laws
03/03/2019
Don’t the ACH Rules govern all aspects of ACH processing and liability?
Can we deny “late claims” from consumers?
02/24/2019
If a consumer makes a claim of an unauthorized ACH Debit after 60 days, we can deny the claim, right?
ACH Stop Payments
02/17/2019
If a consumer wants to put a stop payment on an ACH item, but it’s already posted, all we have to do is return it, right?
Promises that puts your bank at risk
02/10/2019
If our frontline tells a customer “we’ll take care of it” (or similar language) and our operations department finds there is nothing we can do, or we are not obligated to do anything, are we at risk because of the statement?
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