Processing ACH Reclamations from the Federal Government can be challenging! In April 2020 there were updates to 31 CFR Part 210, which meant an update to the Green Book as well. Discussion on the process for deceased account holders and your responsibilities to the Federal Government if they are receiving federal government benefit payments.
The NACHA Operating Rules still apply when processing these payments but the Green Book outlines exceptions when handling mis-directed payments, DNEs (Death Notification Entries) and Federal Government Reclamations. Details on handling Commercial Reclamations will be included, plus an outline of the difference between the two and your liability as an RDFI (Receiving Depositary Financial Institution).