Joint Trades Letter to Treasury re: Delivery of Economic Impact Payments to Americans

The Honorable Steven Mnuchin
Secretary
U.S. Department of the Treasury
Washington, DC

Dear Secretary Mnuchin:

The undersigned bank and credit union trade associations, representing members of all sizes in every state and territory, have worked with the Department of the Treasury over the past several weeks to ensure the safe and secure delivery of Economic Impact Payments (EIPs) to more than 100 million Americans under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). We believe that maximizing electronic disbursements and minimizing paper payments will benefit individual recipients and the country.

The EIP process can be made even more efficient for recipients and the financial services industry if additional clarity is gained in certain operational areas. The undersigned associations have enclosed with this letter a list of questions for the Department of the Treasury – answers to which will provide guidance to financial institutions currently processing electronic and paper check transactions. This important information will help get much-needed relief payments to recipients faster. The responses will not only provide clarity in the near-term, but will also serve as a guidepost for any future relief payment initiatives that may be forthcoming.
It is very important for officials to address the report in yesterday’s The Wall Street Journal that the Department of the Treasury shall seek the return of EIPs sent to the deceased via paper check and Automated Clearing House (ACH) payments. This report is contrary to guidance previously provided by the Department of the Treasury, and contravenes both Nacha Rules and Treasury’s own Green Book that govern federal ACH payments. To reduce confusion amongst recipients and their financial institutions, we request that this matter be addressed with all due haste.

We look forward to continuing our partnership with you and your team to strengthen our dialogue and to facilitate the most efficient Economic Impact Payment process as possible. We would be happy to discuss the issues behind these questions in greater depth at your convenience.

Sincerely,

American Bankers Association
The Clearing House
Consumer Bankers Association
Credit Union National Association
Independent Community Bankers of America
Innovative Payments Association
NACHA
National Association of Federally-Insured Credit Unions