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This is a follow-up to a question I asked on Money.se:

The credit union cited the Automated Clearing House regulations as the reason they reopened my closed account when a third party tried to send money to it.

  • The last paragraph is off-topic on Skeptics. – gerrit Jun 20 '14 at 15:09
  • @gerrit Fair enough. I've removed it. –  Jun 20 '14 at 15:15
  • The claim made by a single call-centre agent isn't notable enough; it could be a simple misunderstanding. The Huffington Post article is about a different situation (withdrawal, not deposit) and doesn't seem to quote a legal obligation (that I could see). – Oddthinking Jun 20 '14 at 15:44
  • @Oddthinking I'm asking the question in the title. How can I make it clearer? (serious, I'm not sure how you'd like me to improve it) - also the claim has been repeated to me several times by different employees of the credit union, and confirmed when I asked for clarification, so as far as I can tell it's their official position. They've gone as far as to say that the only way I can make sure the account is not reopened is to ensure no one ever tries to send money to it. Does that make a difference? –  Jun 20 '14 at 18:42
  • I'd advise reading the actual regulations at http://fms.treas.gov/ach/regulations.html – Sean Duggan Jun 20 '14 at 19:02
  • @Oddthinking I'd really appreciate clarification on why this was closed and what I can do to have it reopened. –  Jul 29 '14 at 14:09
  • Well, the first step was to remove the Huffington Post link. Why? It didn't claim that there was a law. It demonstrated there was no consistency between banks which is evidence that there is no law. – Oddthinking Jul 29 '14 at 14:19
  • The next problem is that you already have an answer on Money.SE. Why ask it again here? – Oddthinking Jul 29 '14 at 14:20
  • But most importantly, you haven't demonstrated a notable claim that there is a law. You've said some call-centre agents have explained it is there internal policy/regulations, but that isn't law. We can't check up on what they actually said. You should ask them to explain further (in writing), take it up with a lawyer or an ombudsman. – Oddthinking Jul 29 '14 at 14:23
  • The literal quote from one employee was "We are required by law to reopen the account." Every other person I talked to at the bank (at least five) confirmed that position. I'm just curious which law they may have been referring to. Their position has not changed, it's not only policy, they are explicitly and repeatedly claiming there is a law that requires them to reopen closed accounts in the event money is sent to those accounts. They never managed to cite said law despite several repeated requests to do so. I'm asking here to determine what law they may be referring to. –  Jul 29 '14 at 14:29

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Consumer Reports did a study on this in 2012, and found that:

...two of the nation’s 10 largest retail banks, Bank of America and Chase, reserved the right to reopen a closed account if there was a subsequent deposit; and Bank of America might also reopen an account after an attempted withdrawal. Chase told us later that it no longer reopens closed accounts, but it had not amended its policy online as of June.

So it appears that while some banks will do this, it probably isn't a legal requirement (otherwise they all should comply).

I've looked over the 2013 NACHA Operating Rules and Guidelines as well, and didn't see anything that requires this action. Whether this has changed (either before or after 2013) I don't know, and I couldn't find a non-paywalled 2014 version.

It does have an explicit return code (R02) for "Account Closed", which leads me to believe that is a valid reason for a bank to reject a payment, rather than being forced to reopen the account.

Is Begot
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