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Handling Tax Refunds on Debit Card

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Question: 
I have a question with regard to Reg CC and the ever changing environment of delivery methods and new accounts. The local tax firms such as H & R Block, Joseph Hewitt, etc. are providing tax refunds via a debit card. The way I understand from a manager of H & R Block, the tax forms are submitted to the IRS for review. Once the IRS approves it and releases the funds to H & R Block, the funds are then captured on a secured server and transferred to the debit card. This would be done by H & R Block. The customer gets this card in the mail. Their PIN is the last 4 digits of their SSN. Their customer is told they can access the cash at any ATM. If we have a new customer to the bank who wants to open an account, and they present one of these debit cards to have the balance on their card as their opening deposit, would that transaction be considered a Next Day Item/Electronic Payment? For us to access the funds, we would have to process it like a Cash Advance, typically a type of transaction done with a credit card. I am thinking it would be an electronic payment, even though there is some manual process to it. Would that be correct? I know the debit card is a substitute for the check, but again to access the funds, we have to go through an electronic medium to get them. We would get an approval code on the machine and record it in our paperwork. With a Cash Advance, once we get that approval, it authorizes our bank to pay the funds. We can then deposit it to an account or give the customer cash. It would be the same process with a debit card.
Answer: 

I think you are over-analyzing the situation. While your bank will receive an electronic settlement for the cash advance, that electronic transaction doesn't go to the customer's new account with you; it goes through the normal settlement accounts used by your bank for cash advances in general.

I recommend you treat the scenario much more simply: Have the customer obtain the cash advance in the customary manner and have the cash credited to the new account. I doubt that the amount will approach the CTR trigger level, but if so, and if the same teller handles both sides of the transaction, the cash account can be annotated to show that no cash changed hands.

The result: The new account is funded with cash, which will be available for next-day withdrawal.

First published on BankersOnline.com 4/11/11

First published on 04/11/2011

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