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Course description

This session outlines a banks responsibilities to the Federal Government if a beneficiary is deceased but still receiving benefit payments. The NACHA Operating Rules still apply when processing these payments but the Green Book outlines the exceptions when handling DNEs (Death Notification Entries) and Federal Government Reclamations. We will also explore the bank’s liability for other types of Federal Government payments and other types of reclamations a bank can expect to receive. Participants demonstrate their knowledge by successfully calculating the banks liability for given situations and by passing a course exam.


  • How and when 31 CFR Part 210 applies to payments
  • How and when to process Death Notification entries
  • Bank notification of knowledge of date of death of a customer
  • Timeframes, tips, and best practices when returning ACH entries of deceased customers
  • Return Reason Codes to use when returning certain benefit payments
  • Processing Federal Government Reclamations, including timeframes and limiting the banks liability
  • Difference in liability and handling between Commercial and Government Reclamations
  • Tips on handling incoming ACH entries on accounts where the beneficiary is deceased
  • What to do when the government claims your customer is deceased, but they are not
    Advanced subject
    2.4AAP Credits


This informative session is designed for anyone in the bank responsible for managing payments risk including Operations, Operations Managers, Risk Manager, Compliance, Compliance Officer, Auditors, Electronic Banking, Branch Manager, Call Center, and Trainers. 


Rayleen Pirnie

Rayleen is the founder and owner of RP Payments Risk Consulting Services, LLC. based in Missouri. She is a nationally recognized payments risk and fraud expert. Her programs educate financial institutions and businesses on topics ranging from payments fraud to information security. She is the author of several payments risk and fraud blogs geared toward helping organizations recognize threats and protect themselves from loss.Always interested in Risk Management, Rayleen has supported many notable organizations over the years. She is a member of the International Association of Financial Crimes Investigators, supporting their training programs since 1998. She sat on NACHA’s Risk Management Advisory group for two terms, and assisted with FSISAC’s first CAPP exercise. For 16 years Rayleen has spoken at national and regional conferences. Recent events include NACHAs Payments Conference, the American Bankers Association Risk Management Forum, the Security Matters annual conference at Murray State University, the Risk Management Association, and the Federal Reserve Bank of Kansas City Risk Management Conference.

Course curriculum

  • 1


    • Advanced ACH: Death Notification Entries and Reclamations: A Banks Responsibilities

  • 2


    • Slides

    • Green Book, Chapter 5

    • Attendance Sheet

    • Questions and Answers