Yes, you may change the inactive status to active status on an inactive account if the customer has other active accounts with your bank. However, you should check your account agreements to make sure that any changes you make are consistent with your disclosed practices.
The Uniform Disposition of Unclaimed Property Act does not consider a customer’s inactive account to be inactive or “abandoned” if the customer increases or decreases the amount of funds in any other account at the financial institution or otherwise is actively engaged in a relationship with your bank. Other than the Uniform Disposition of Unclaimed Property Act, we are not aware of any law or regulation that addresses the status of an inactive account when there are other active accounts maintained by the same customer at the same bank.
For resources related to our guidance, please see:
- Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/2(a)(4) [Repealed effective 1/1/18] (“The following property held or owing by a banking or financial organization is presumed abandoned: (a) Any demand, savings, or matured time deposit with a banking organization, together with any interest or dividend thereon, excluding any charges that may lawfully be withheld, unless the owner has, within 5 years: . . . (ii) increased or decreased the amount of funds in any other account the owner has with the banking organization; or (iii) engaged in any other relationship with the banking organization, including payment of any amounts due on a loan.”)