Compliance and risk professionals should consult with their legal counsel and operational staff to consider the operational implications of EIPs.
Treasury will be treating these payments as if they were tax refunds with all the accompanying rules. The processing of Federal tax refunds has very specific liabilities assigned. There are three potential scenarios:
If the tax-preparer or taxpayer makes an error, the tax-preparer or taxpayer will be responsible; the government will not help.
If the financial institution moves the Entry to an account other than the account identified in the Entry, the government will not help, and the RDFI will be liable.
If the IRS makes an error, the government will help with resolving the error.
If your institution returns an EIP ACH Direct Deposit, that payment will be redistributed as a check payment by the Treasury.
Payments, both via ACH and Check, will be distributed in weekly cycles. There is no current list of when a specific payment will be distributed.