Hello,
I am trying to research any restrictions on the ability to accept an incoming wire that does not contain an account number only a customer/beneficiary name.

I have looked at Reg J & UCC 4A but only see guidance when account number doesn't match name (4A-207) Misdescription of Beneficiary.

Section 4A-207(a) indicates if payment order refers to nonexistent or unidentifiable person or account, no person has rights as beneficiary.


So if no account is identifiable on payment order (incoming wire) then should we be rejecting?

Appreciate any help with this as I may be overthinking it!

A wire with a name (valid name of actual customer) is valid without an account number. There is no need to reject it.

Thank you John,

Would you be able to point me to section of regulation that describes this? What if the benefeciary name is a common one and Bank has more than 1 customer by the same name? I only see the safe harbor for accepting wire using account number. Wouldn't it be a risk for Bank to contact the presumed beneficiary and request account number from them (in the event they have more than 1 account)?
Can the sender later claim that wire was not actually meant for that beneficiary based on the fact that they did not provide an account number? For example if they get into a dispute with beneficiary?

Appreciate the help and input,
Thanks

John was just offering an observation, not paraphrasing a regulation.

The most detailed guidance about what another bank must send to you is FIN-2010-G004. There, the originating bank is not obligated to include the recipient's account number unless they received it from the originator. (The purpose of this rule relates more to law enforcement, not bank operations or administration of the wire transfer function in a beneficiary bank.)

Regardless of the sending bank's responsibilities, the receiving bank is entitled to require a account number as a condition of accepting the wire if it chooses to do so. Your simplest motivation would be that the customer has 3 accounts and you insist that the originating bank provide the correct number rather than accepting the responsibility for contacting your customer with the query.

Great thank you! I will review this guidance. Appreciate the response, it answers my question as to what we should accept and what we may not be comfortable accepting. Now will just need to address from a customer service standpoint if we are going to reject a wire whwn no account number is designated.
Thanks again.

Try this thought: Assume you have three customers named Ken Golliher at different addresses. You receive a wire transfer of $10,253 for credit to Ken Golliher. The wire includes information on the sender and the city or country whence it came.

You decide that one of your Ken Gollihers will want these funds, so you pick up the phone and call Ken #1. "Mr. Golliher," you say, "this is MariaV at XYZ Bank. We have received a wire transfer naming Ken Golliher as the recipient. Are you expecting such a wire?" If Ken #1 says no, you thank him and bid him a good day.

You repeat that with Ken #2. Ken #2 says he is expecting a wire transfer but asks you how much the wire is for. You, of course, wisely turn the question back on him and suggest that he will need to give you the amount. If he says $10,253 and then tells you whence it came, you can comfortably credit Ken #2's account and suggest that if he expects future wires, he request that the sender include his account number to avoid problems. If Ken #2 can't provide you with information satisfying you that the money is his, you tell him you'll need to investigate further, and bid him adieu. Then you contact Ken #3.

Or you simply send it back indicating you aren't able to identify the proper recipient without an account number.

Option 1 involves some effort and time in the name of customer service. Option 2 is an easy way out, but risks customer disappointment.

When I managed our wire department, we always returned wires if there was no account number. I was concerned with putting funds into an account where we didn't have record that that was where they were intended to go. What if the funds were placed into an incorrect account number and the person spent the money? I understand that the recipient wouldn't be allowed to do this but I felt more comfortable requiring the account number being sent with the wire rather than having to possibly chase down misdirected funds and correct that error. CYA and all that.