Compliance Alliance Q&A 4/28/2020



Q: Should the bank return stimulus checks that are received through direct deposit for deceased or divorced recipients? Is there a possibility of reclamation?


A: According to a recent call in which several members of the Treasury spoke, banks may accept even single-party deceased payments because they have been screened and eligible based on date of death.  As for divorced parties, Banks may pay into joint accounts if that's how the payment is made even if the bank is aware the parties are now divorced. The Treasury members indicated that there should be no reclamation claim on the bank if $2,400 were deposited into the account, even if the parties are divorced. They indicated that the Treasury has no authority to hold the bank liable as long as the bank posted it properly according to the account number. 


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