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ReclamationsError processing SSI fileHolding Payments Under no circumstances should an RDFI hold payments indefinitely in a suspense account, or by any other means, nor should payments otherwise be held if any of the conditions apply on when to return a payment. Holding payments may constitute a breach of the RDFI's warranty for the handling of federal government ACH payments under 31 CFR 210 and could result in an RDFI's inability to limit its liability. If the survivors or other withdrawers state that the withdrawn post-death payments have already been repaid to the federal agency, the RDFI should obtain a written confirmation from those persons, including a copy of the front and the back of the check(s). If all post-death payments have been repaid by the survivor(s), the RDFI should not receive a Notice of Reclamation. If a Notice of Reclamation is received, the RDFI must return it to the Government Disbursing Office that issued it, attaching an explanation and any other documentation it has. The RDFI will not be held liable for any post-death payments that have already been repaid to the originating agency. Handling Survivor Requests not to Return Post-death Benefit Payments The RDFI may be asked by the survivor(s) not to return post-death benefit payments because the survivor is still entitled to all or part of the payments. In such cases, the RDFI still should return the payment and advise the survivor to contact the appropriate federal benefit agency with any questions.
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