Federal Reclamation Entries: When RDFIs Take a Loss

Federal benefit payments follow rules that are very different from standard ACH processing. When a federal agency issues a Notice of Reclamation after the death or legal incapacity of a benefit recipient, the Receiving Depository Financial Institution (RDFI)—not the beneficiary’s estate—bears liability to the federal agency. Understanding when and how that liability applies is critical for operations staff responsible for ACH exceptions and post-death processing.
In under 30 minutes, this course explains how to recognize federal benefit entries, the regulatory framework under 31 CFR Part 210 and the Treasury’s Green Book, and how Death Notification Entries (DNEs) and Notices of Reclamation (NORs) trigger an RDFI’s responsibilities. You will also learn how limited liability works, why certification accuracy matters, and the operational pitfalls that most often cause RDFIs to lose their liability protection.