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DNE Notification on ACH

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Question: 
What are the compliance rules involved with DNE notification on ACH's?
Answer: 

There are none. The DNE notification is provided via the ACH by government agencies to get death notices to RDFIs sooner. It is strictly (so far) an "FYI" and requires no specific action.

However, because of the government's reclamation process, RDFIs receiving DNE notices may wish to take steps to set up automatic rejects of future direct deposits of government benefits, etc. They may also have a duty to act upon the information in the death notice to flag accounts to prevent post-mortem withdrawals.

Because of the possibility of errors in DNEs (not frequent, but possible), RDFIs should verify the information before acting upon it.

First published on BankersOnline.com 01/19/04

Answer: 

Update (10/11/2023) by John Burnett:
Things have changed in the 19 years since we published my answer above.

Treasury Department Fiscal Service regulations (31 CFR Part 210: Federal Government Participation in the Automated Clearing House) now require that, once a financial institution learns of the death of a customer whose account has been receiving direct deposits of federal benefits payment, the financial institution MUST return any such direct deposits for the benefit of the deceased customer that are received AFTER the institution has knowledge of the customer's death. Receipt of a DNE puts the institution on notice of the death, but such knowledge can also come from other sources.

Take care, however, not to flag both owners of a joint account who have been receiving direct deposits. The surviving co-owner's benefits should not be blocked or returned.

First published on 01/19/2004

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