Only government benefit payments are subject to reclamation.

Agencies that initiate reclamations must do so within 120 calendar days after the date that the agency receives notification of the death.

An RDFI is not liable for any post-death payments made more than six years prior to the date of the notice of reclamation, except under the following circumstance:

"If the account balance at the time the RDFI receives the notice of reclamation exceeds the total amount of all post-death or post-incapacity payments made by the agency during such six-year period, this limitation shall not apply and the RDFI shall be liable for the total amount of all payments made, up to the amount in the account at the time the RDFI receives the notice of reclamation and has had a reasonable opportunity (not to exceed one business day) to act on the notice." [31 CFR Part 210.10(d)]

RDFI REACTION TIME: The RDFI, upon receipt of the government's Notice of Reclamation, has UP TO ONE BUSINESS DAY to react to that Reclamation by determining the account balance, and by preventing any further withdrawals of post-death Government benefit payments from the account, if possible under the terms of the contract with the account holder.

RDFI RESPONSE DEADLINE: The RDFI has up to 60 days from the issue date of the Reclamation to provide a full and accurate response to the proper Government Disbursing Office. Failure to respond timely may result in a debit to the RDFI's Federal Reserve account or the account of its correspondent for the total amount of the Reclamation. This debit action will be final.

It is important that RDFI's understand the reclamation process and the associated liabilities. RDFI liability is discussed in Section 2. Section 3 provides RDFI guidance on processing reclamations.

Note: Recipients may be receiving multiple benefit payments from the same or different federal agencies.

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