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A customer passed away on May 6. The bank received a Social Security payment for the month of April, while the customer was still alive. Can we accept the payment? – IBA Compliance Connection

IBA Compliance Connection

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A customer passed away on May 6. The bank received a Social Security payment for the month of April, while the customer was still alive. Can we accept the payment?

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Yes, we believe the bank may accept the Social Security payment for the month of April. The Social Security Administration requires you to return the payment that is received for the month of death or any subsequent months. Because the customer passed away in May, we believe you can accept the payment for the month of April, but you must return any subsequent payments.

For resources related to our guidance, please see below:

  • Social Security Publication No. 05-10008 (November 2009) (“If the deceased was receiving Social Security benefits, you must return the benefit received for the month of death or any later months. For example, if the person dies in July, you must return the benefit paid in August.”)