Hi everyone! I just wanted to clarify something with regards to the new garnishment rule. Instead of having seperate account numbers for savings, checking, money market, etc.we use sub accounts. So savings may be 123456 sub account # 1 and checking 123456 sub account # 6. When I read through the new rule, I interpruted it to mean that we would have to perform an account review for each of the sub accounts seperately. However, I was talking to someone at a different instituion today and they said they did not think they needed to be done seperately because they were under one main account number. Of course this person also told me that Levies were not included in the new rule, it was strictly garnishments, although the definition clearly indicates levy so.... Nonetheless, it got me thinking, so what is everyone else's take on this?

Also, I was curious if anyone was putting together forms for employees to use during the account review process to help them keep track of deposits and such on? I am trying to put together some new check lists and such and was curious at what others were providing their employees with.

Dawn in MN

IRS levies are not included, only county/state levies.

And state tax levies are not included unless issued by a court.

As for the sub account issue, here's some helpful text from page 9941 of the Federal Register:

So, if the depositor can receive direct deposits to more than one sub account, you have to do the analysis per sub account.

If your system allows you to aggregate sub accounts for research, showing all activity for the full collection of sub accounts, doing the analysis at the master account level could give you different results for a determination of protected balances, particularly if one or more of the sub accounts is overdrawn at the time (the master account probably reflects a net positive balance). Keep your analysis at the sub account level to ensure that you don't report the wrong protected balance amount(s).