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SSA Check Deposited to Business Account

Question: 
We have an customer that is having his SSA check deposited to a business account (corporation). As a RDFI, when receiving pre-notifications for Government payments, is the bank responsible for verifying that the name and TIN on the prenote match the name and TIN on the deposit account? Or is the bank only responsible for verifying that the deposit account is a valid account.
Answer: 

Answer by Randy Carey: Technically you are only responsible to make sure the account number is valid. However, there are numerous things wrong with this situation and I would call the customer and tell them to change it because you will be returning all future deposits (allowed under NACHA rules) after a reasonable time for them to make the change.

Answer: 

Answer by John Burnett: To my knowledge, Treasury does not send a prenotification entry for new direct deposit arrangements. But if you become aware that your corporate customer's account is receiving a direct deposit of funds belonging to an individual, you should follow Randy's advice.

First published on BankersOnline.com 4/1/13

First published on 04/01/2013

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