02/23/2025
Per bank policy, we have always stated that if we cash a check for a customer (it is never deposited into their account) and the check is returned, we cannot offset their account for the returned check. We (the bank) have always thought this was a regulation, but cannot find it anywhere.
Is a bank permitted (or not) to debit the customer's account when a cashed item is returned?
02/02/2025
I have been in our bank's treasury department for many years and never been part of, or seen, a Positive Pay audit. Our new auditor wants to put an audit process in place for it. What would be the compliance reason to perform an audit on Positive Pay?
02/02/2025
We are a [redacted vendor name] bank using [redacted vendor name] AML software. We have noted an increase in small check fraud between $100.00 and $5,000.00 at our teller stations and ATM deposits. Currently, with manual reports worked daily and certain alerts within our software, we are able to catch the larger dollar amounts in check fraud.
We want to know if any banks using the same software know of anything that could help us catch more of these smaller amounts in attempts to reduce loss, whether it be manual reports through our vendor, reports in [redacted], or parameters that can be changed in our vendor software.
11/24/2024
We have a savings account with an ACH that we are returning NSF. Can we charge the NSF fee if the ACH would have overdrawn the account?
09/08/2024
We have an individual account that has been receiving recurring ACH debits monthly. The account owner died 6 years ago. The bank just found out about the death only days ago. No personal representatives have come forward or are known to contact. The most recent ACH debit was paid and overdrew the account. The account has now been overdrawn for 45 days.
Can we return the ACH debits that occurred after the date of death? Although the debits have been occurring for years, the bank just became aware of the death of the account owner.
05/14/2023
Does an online bank (such as Ally Bank or go2bank) have to provide customers with an Image Replacement Document (IRD) when checks deposited via mobile Remote Deposit Capture (mRDC) are returned?
If no, does it then become the responsibility of the payee to work with the maker of the check to recoup the funds?
04/30/2023
Is it customary to file a SAR when a customer's payroll check is returned as NSF? The check is not redeposited and it appears the employer corrects this by paying the employee in cash for those returned items. The check amounts range from $600-$900. There have been a total of 9 checks within a yearlong period.
12/12/2021
When mailing a chargeback to a customer, is it required to include a brochure explaining Check 21? We give out disclosures at account opening explaining Check 21 and since it's been in place since 2004 do we really need to send one with every chargeback?
04/19/2020
We have an item that was returned with the incorrect return reason code. It was returned as a forgery but should have been an endorsement. The item is payable to a business and endorsed by an individual. The payee claims to have not received the item in the mail. We received the item back as a late return claim. Can we return the item again for the correct return reason? What is the time frame for an improper endorsement?
05/19/2019
For an ACH transaction we (RDFI) have received, we believe a third party made the payment to an account and we (as RDFI) would like to return it. May we return it using the return code R23? R23 description sounds as if the recipient account holder should return the transaction.