Customer Dies Same Day as SSA Deposit

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Question:

We have a customer that receives SSA on the 8th of the month. This customer died August 8th, the same day her Social Security went into her account. Do I have to send the money back to SSA? Everything I read says if they die before the deposit then I must return, but nothing about the same day.

Answer:

An excerpt from 31 CFR 210.10(a): "An RDFI shall return any benefit payments received after the RDFI becomes aware of the death or legal incapacity of a recipient or the death of a beneficiary, regardless of the manner in which the RDFI discovers such information."

I doubt you knew of your depositor's demise before the SSA deposit was received for credit to his account. You should ensure that the September 8 payment is returned (but it's not likely to show up).

His September 8 payment was earned for the month of August, so even if you were to send it back, his survivors would get it back (eventually).

First published on BankersOnline.com 9/17/12