Green Book 5. Reclamations

A Guide to Federal Government ACH Payments 5-1

5 Reclamations

Overview

In this chapter...

Section 1: Background......................................................................................................................................5-3

Payments Subject to Reclamation........................................................................................................................5-3

Section 2: Liability of a Receiving Depository Financial Institution (RDFI)...................................5-4

A: Full Liability .............................................................................................................................................................5-4

B: Limiting Liability ...................................................................................................................................................5-4

C: Calculating the Limited Liability Amount....................................................................................................5-5

Table 2-A: Calculating the Limited Liability Amount.....................................................................................5-5

Section 3: Reclamation Procedures..............................................................................................................5-6

A: Notification of Death............................................................................................................................................5-6

Title 31 CFR part 210 ....................................................................................................................................................5-7

What to do upon Notification of Death with Payments Already Posted and Subsequent Payments

................................................................................................................................................................................................. 5-8

No Holding of Payments...............................................................................................................................................5-8

Repayment by Survivors...............................................................................................................................................5-8

Handling Survivor Requests not to Return Post-death Benefit Payments ............................................. 5-9

B: Notice of Reclamation .........................................................................................................................................5-9

Table 3-A: Notice of Reclamation (FS Form 133).............................................................................................5-9

Sample of Notice of Reclamation (FS Form 133)..............................................................................................5-9

Table 3-B: How to Respond to the Notice of Reclamation.............................................................................5-10

ACH Debit Authorizations............................................................................................................................................5-11

Incomplete or Inadequate RDFI Replies ............................................................................................................... 5-11

Section 1 defines reclamation and provides some background information on the subject.

Section 2 covers an RDFI’s liability in the reclamation process. Topics include full and limited 

liability, calculating the limited liability amount, and exceptions to the liability rule.

Section 3 gives RDFI’s guidance on processing reclamations using the Automated Reclamation 

Processing System (ARPS) utilizing Pay.gov and provides an updated contact list for individuals 

needing additional information assistance with reclamations.
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5-2 A Guide to Federal Government ACH Payments

Time Limits for Federal Reclamations................................................................................................................5-12

Follow-up to the Notice of Reclamation (Fiscal Service-2942)................................................................. 5-13

Federal Agency Collection from Withdrawers................................................................................................ 5-13

Debit of the RDFI’s Account.....................................................................................................................................5-13

Table 3-C: Debit of the RDFI’s Account...............................................................................................................5-13

How to Identify Debits using the Reclamation Ticket Number ................................................................5-14

Table 3-D: Transaction Codes for ACH Reclamations.................................................................................. 5-14

C: Errors in Death ...................................................................................................................................... 5-15

If the Person did not Die...........................................................................................................................................5-15

Types of Evidence....................................................................................................................................................... 5-15

Table 3-E: Accepting the Proof...............................................................................................................................5-15

Table 3-F: Rejecting the Proof............................................................................................................................... 5-16

Restarting Payments .................................................................................................................................................. 5-16

If the Date of Death is Wrong..................................................................................................................................5-16

Learning of an Error After Completing a Reclamation..............................................................................5-17

Table 3-G: Worksheet for Adjusting the Outstanding Total if the Date of Death is Wrong.......5-17

D: Subsequent Notice of Reclamation ..................................................................................................... 5-17

What to do ..............................................................................................................................................................5-17

Previous debit.......................................................................................................................................................5-17

E: Contacts ......................................................................................................................................................5-17
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A Guide to Federal Government ACH Payments 5-3

Section 1: Background

Reclamation is a procedure used by the federal government (government) to recover benefit 

payments made through the ACH to the account of a recipient who died or became legally 

incapacitated or a beneficiary who died before the date of the payment(s).

The government’s right to reclaim funds is established in the United States Code, including at 31

U.S.C. § 3720 and implemented in Title 31 of the Code of Federal Regulations part 210, subpart B, 

and section 210.10(a). The government’s reclamation process is found in 31 CFR 210.9 through

210.14. The reclamation provisions of 31 CFR part 210 completely preempt the reclamation 

provisions of the Nacha Operating Rules & Guidelines with respect to federal benefit payments.

 Effective January 1, 2023

x All reclamation responses must be submitted through the Automated Reclamation Processing 

System (ARPS) located in Treasury’s Pay.gov web portal (except for responses by DFAS and any 

Treasury-approved exceptions). Note: We will no longer accept remittances related to 

reclamation responses.

x Exceptions: All exceptions must be approved on a case-by-case basis by Bureau of the Fiscal 

Service and requests may be sent to: pfc-reclamations@fiscal.treasury.gov

By accepting a recurring benefit payment from the government, an RDFI agrees to the provisions of 

31 CFR part 210, including the reclamation and debiting of the RDFI’s FRB master account for any 

reclamation for which it is liable. The RDFI also agrees to the liability provisions of the federal 

reclamation regulations found in 31 CFR part 210, subpart B, and affirms this agreement each time 

the RDFI accepts and credits an ACH payment on behalf of a depositor.

Note: In this chapter, “death” always means the death or legal incapacity of a recipient or the death of 

a beneficiary. And “government” always means the federal government.

Payments Subject to Reclamation

Only government benefit payments are subject to reclamation.

Payments Subject to Reclamations Payments not Subject to Reclamations

Social Security benefit or disability (SSA) 

Supplemental Security Income (SSI) 

Black Lung disability (Dept. of Labor)

Military and Coast Guard retirement, including 

allotments from military retired pay (DoD) 

Civil Service annuity (OPM)

Veterans Administration benefits (VA) 

Railroad Retirement Board (RRB) annuity 

US Coast Guard

Worker's compensation (FECA) 

DC Pensions

Compensation Act (Dept. of Labor)

Any other federal retirement or annuity

Federal salary, allotments, and travel payments

U.S. savings bond payments 

Vendor/miscellaneous payments 

IRS tax refunds

Discretionary allotments

Public debt payments (TreasuryDirect) 

Other types of federal ACH payments

Note:. For post-death payments not affected by 

reclamation, adjustments must be made between 

the authorizing federal agency and the 

recipient’s survivors or estate. 
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5-4 A Guide to Federal Government ACH Payments

Section 2: Liability of a Receiving Depository Financial 

Institution (RDFI)

A: Full Liability

An RDFI is liable for ALL benefit payments received after the death or legal incapacity of a recipient 

or death of a beneficiary, unless the RDFI meets the qualifications for limiting its liability (see B. 

Limiting Liability below).

If the RDFI fails to meet the qualifications for limiting its liability, the RDFI will be held liable for all 

post-death benefit payments received after the death or legal incapacity of a recipient or death of a 

beneficiary. The RDFI will be debited for the full amount of the reclamation. This debit action will 

be final, with the exception of a valid protest.

Note: If no post-death benefit payment has been received at the time the RDFI learns of the death, the 

RDFI may also contact the paying agency (see Contacts, Chapter 7).

B: Limiting Liability

An RDFI may qualify to limit its liability if it:

x certifies it did not have actual or constructive knowledge* of the recipient’s death or incapacity 

at the time of the deposit of any post-death benefit payments,

x returns all post-death benefit payments it receives after it learns of the recipient’s death (but 

not post-death benefit payments it received before it learned of the death), and

x adequately responds to the Fiscal Service Form FS Form 133, “Notice of Reclamation,” within

60 calendar days from the date of the notice by using the Automated Reclamation Processing 

System (ARPS).

Exception: Only reclamation responses by DFAS and any Treasury-approved exceptions 

(evaluated on a case-by-case basis) are not required to respond using ARPS. Note that these 

responses must meet all other requirements for limiting liability, including receipt by Fiscal 

Service within 60 days.

*Note: In this chapter “constructive knowledge” of the death means that the RDFI would have learned 

of the death if it had followed commercially reasonable business practices. “Actual or constructive 

knowledge” is defined in Treasury’s regulations at 31 CFR § 210.2(b).

Exception to Liability Rule

An RDFI will not be held liable for post-death benefit payments sent to a recipient acting as a 

representative payee or fiduciary on behalf of a beneficiary in the event that the beneficiary dies. In 

this situation, the paying agency will not initiate a reclamation but will instead pursue recovery of 

any post-death benefit payments from the representative payee.

Requirement to Return Post-Death Benefit Payments

It is important to understand that once a payment has been credited to payee’s account, it becomes 

the property of the account holder. In the case of post-death payments, the payments become 

property of the joint account holder or decedent’s estate. The government cannot legally authorize 

or direct an RDFI to take funds already credited to an account and return them to the government.
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A Guide to Federal Government ACH Payments 5-5

This is the reason that RDFIs are directed only to return post-death payments that they receive 

after they become aware of the payee’s death, using an R14 or R15 return reason code. Such returns

are legally permissible because the payments have not been credited to the recipient’s account and

therefore have not become property of the joint account holder or decedent’s estate.

It is up to each RDFI to consider its policy as an institution as to what steps it may wish to take, if 

any, upon learning of the death of a recipient in order to preserve funds in the account pending 

receipt of a Notice of Reclamation. Some RDFIs, upon becoming aware of an account holder’s death, 

perform an account analysis before receiving an NOR and voluntarily return post-death payments 

that were credited to the account before the RDFI learned of the death. RDFIs are cautioned that 

Fiscal Service does not authorize or direct RDFIs to debit or otherwise affect the account of a 

recipient, including to return post-death payments already credited to an account. However, Fiscal 

Service will accept pre-NOR returns of post-death payments provided that they are made 

electronically using an R14 or R15 code.

C: Calculating the Limited Liability Amount

If an RDFI qualifies for limited liability, the RDFI will only be debited for the ACH 45-day amount.

The ACH 45-day amount is the dollar amount of the post-death benefit payments received within 

45 calendar days following the death.

Note: The limited liability amount may not exceed the outstanding total on the Notice of Reclamation. 

The outstanding total is the total amount of all the post-death benefit payments.

Table 2-A: Calculating the Limited Liability Amount

Example 1: Four payments of $200 each were received after death. The first benefit payment 

was received within 45 days after the date of death (i.e., ACH 45-day amount = $200). The RDFI had no 

actual or constructive knowledge at the time the post-death benefit payments were received or 

withdrawn.1 No additional benefit payments were received after the RDFI had knowledge

of Reclamation2

Scenarios 1-5 Scen.1 Scen.2 Scen.3 Scen.4 Scen.5

Total Amount of post-death payments on the Notice of Reclamation $800 $800 $800 $800 $800

Amount of the Account Balance paid by RDFI in response to the Notice $300 $300 $750 $0 $800

Amount due from withdrawers $500 $500 $50 $800 $0

Amount collected by government from withdrawers $250 $500 $0 $0 $0

Outstanding total $250 $0 $50 $800 $0

Amount to be debited from the RDFI's federal reserve account = $200

(lesser of Outstanding Total or ACH 45-day amount)

$0 $50 $200 $0

1 RDFI had no actual or constructive knowledge of the death at the time of deposit or withdrawal of any post-death

benefit payments.

2 RDFI accurately responds to the Notice of Reclamation so that the appropriate amount is received by the

government disbursing office within 60 calendar days of the date on the Notice.
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5-6 A Guide to Federal Government ACH Payments

Example 2: Four payments of $200 each were received after death. Three of the benefit 

payments were received before the RDFI had actual or constructive knowledge of the death. The 4th 

benefit payment was received by the RDFI after it had received a DNE and the RDFI promptly returned 

the payment using an R15 return reason code.1 The 1st and 2nd benefit payments were received within 

45 days following the date of death (4th benefit payment will not be listed on the Notice of 

Reclamation since it was promptly returned by the RDFI).

of Reclamation2

(lesser of Outstanding Total or ACH 45-day amount)

1 RDFI is obligated to return any post-death benefit payments that the RDFI receives after becoming aware of the

recipient’s death. RDFI is not obligated or authorized to return post-death benefit payments that the RDFI received before

becoming aware of the recipient’s death.

2 RDFI accurately responds to the Notice of Reclamation so that the appropriate amount is received by the government

disbursing office within 60 calendar days of the date on the Notice.

Section 3: Reclamation Procedures

A: Notification of Death

An RDFI must immediately return any post-death benefit payments received after the RDFI 

becomes aware of the death or legal incapacity of a recipient (but not post-death benefit payments 

that the RDFI received before becoming aware of the recipient’s death). If the RDFI learns of the 

death or legal incapacity of a recipient from a source other than the federal agency, the RDFI must 

notify the sending agency of the recipient’s death. An ACH return using return reason code R15 or 

R14 constitutes proper notification to the federal agency. When returning payments, the RDFI 

should ensure that the date of death in the addenda record be in YYMMDD format. The RDFI should 

also provide notification to the account owners, as a courtesy.

Scenarios 1-5 Scen.1 Scen.2 Scen.3 Scen.4 Scen.5

Total Amount of post-death payments on the Notice of Reclamation $600 $600 $600 $600 $600

Amount of the Account Balance paid by RDFI in response to the Notice $300 $300 $550 $0 $600

Amount due from withdrawers $300 $300 $50 $600 $0

Amount collected by government from withdrawers $50 $300 $0 $0 $0

Outstanding total $250 $0 $50 $600 $0

Amount to be debited from the RDFI's federal reserve account = $250 $0 $50 $400 $0
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A Guide to Federal Government ACH Payments 5-7

Notification of death of a recipient by any source constitutes notification for all federal benefit

payments received by that recipient. The following are some examples of ways that the RDFI may 

learn of the death of their account holders:

x Receipt of a Death Notification Entry (DNE) - A DNE is a notification of a benefit recipients 

death sent from an originating government agency (e.g., SSA, RRB, or OPM) to the RDFI,

x Receipt of a federal government Notice of Reclamation, (FS Form 133),

x Any contact or request to withdraw funds from an Estate, Executor, Administrator, Public 

Administrator, Personal Representative, Conservator or other representative of such Estate. 

Note: Any release to an executor or other party clearly acting on behalf of the deceased 

person or their estate will be deemed by the government to have demonstrated the RDFI’s 

knowledge of the death,

x A pertinent reference to or from a Probate Court, a funeral home, or Letters Testamentary.

x Credible oral or written report of death,

x Credible death information obtained by the RDFI’s inquiry into a dormant account, or

through other RDFI internal screening processes,

x Credible personal awareness of the death by the RDFI’s staff, or

x Credible death notice received in the mail from any source.

Note: If at the time the RDFI first receives information of death, all or part of the post-death benefit 

payments have already been withdrawn from the account, the government does not authorize or 

direct the RDFI to try to recover the funds from the withdrawer. If the RDFI does so, it acts under its 

own authority in terms of its contract with its depositor or under state law.

Title 31 CFR part 210

This regulation defines when a federal agency as well as an RDFI has actual or constructive 

knowledge of the death:

A federal agency or RDFI has actual knowledge of the death or legal incapacity of a recipient, or the 

death of a beneficiary, when it receives information, by whatever means, of the death or legal 

incapacity and has had a reasonable opportunity to act on such information or that the federal 

agency or RDFI would have learned of the death or legal incapacity if it had followed commercially 

reasonable business practices. See 31 CFR § 210.2(b).

The phrase “commercially reasonable business practices” is a flexible concept since, for 

example, what is a commercially reasonable practice for a large bank may not be 

commercially reasonable for a small rural bank, and vice versa.

In March 2020, Fiscal Service revised this definition to include parameters for when an agency is 

presumed to have constructive knowledge of a death or legal incapacity. Specifically, a federal 

agency is presumed to have constructive knowledge of a death or legal incapacity at the time it 

stops certifying recurring payments to a recipient if the agency (1) does not re-initiate payments to 

the recipient and (2) subsequently initiates a reclamation for one or more payments made to the 

recipient. See 31 CFR § Part 210.2(b) This presumption is rebuttable in cases where an agency can 

demonstrate that it stopped certifying recurring payments to a recipient for a reason other than 

death.
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5-8 A Guide to Federal Government ACH Payments

What to do upon Notification of Death with Payments Already Posted and Subsequent 

Payments

When an RDFI receives actual or constructive knowledge of the death of a recipient, it must return 

all subsequent post-death benefit payments, meaning all post-death payments received after the FI 

learns of the death, to the government disbursing office using return reason code R15 or R14. The 

RDFI must also notify the sending agency of the recipient’s death. An ACH return using return 

reason code R15 or R14 constitutes proper notification to the federal agency of the recipient’s 

death. An RDFI can, if they so choose, return by ACH any post-death benefit payments that were 

already posted to the recipient’s account before the RDFI received actual or constructive 

knowledge of death, by ACH, without waiting for a Notice of Reclamation, but the RDFI is not 

required or directed to do so.

R15 Beneficiary Deceased

The beneficiary is the person entitled to the benefits. In this case, there is no representative payee 

or guardian involved.

R14 Representative Payee (or Guardian) Deceased or Incapacitated

The representative payee (or guardian) is the person who receives benefit payments on behalf of 

the (under aged or incapacitated) beneficiary. E.g., payment is payable to “John Doe, for [another 

person]”.

Any information of the death of a representative payee that is received by the RDFI or any of its 

employees, from whatever source, establishes the full legal liability for ALL SUBSEQUENT postdeath federal benefit payments from all agencies, as well as any post-death benefits in the account, 

which the RDFI then allows to be withdrawn.

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

agencies. An RDFI should ensure that they are returning all federal benefit payments subject to 

Reclamation. If a Financial Institution needs to correct errors in their use of reason codes when 

returning funds, they should contact the agency receiving the return. Please see Chapter 7, Contacts, 

for major paying agency contact information.

No Holding of Payments

Under no circumstances should an RDFI hold benefit payments indefinitely in a suspense account, 

or by any other means, nor should benefit payments otherwise be held if any of the conditions 

apply on when to return a benefit payment. Holding benefit payments may constitute a breach of 

the RDFI’s warranty for the handling of federal government ACH payments under 31 CFR part 210 

and could result in an RDFI’s inability to limit its liability.

Repayment by Survivors

If the survivors or other withdrawers state that the withdrawn post-death benefit payments have 

already been repaid to the federal agency, the RDFI should obtain a front and back copy of the 

check(s) and/or a receipt from the federal agency.

If all post-death benefit payments have been repaid by the survivor(s), the RDFI should not receive 

a Notice of Reclamation. However, if a Notice of Reclamation is received, the RDFI must complete 

the electronic FS-133 in ARPS within 60 calendar days. The RDFI is not liable for any post-death 

benefit payments that have already been repaid to the originating agency.
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A Guide to Federal Government ACH Payments 5-9

Handling Survivor Requests not to Return Post-death Benefit Payments

The RDFI may be asked by the survivor(s) not to return post-death benefit payments because the 

survivor believes he or she is entitled to all or part of the payment(s). In such cases, the RDFI should 

still return the benefit payment and advise the survivor(s) to contact the appropriate federal

benefit agency (see Chapter 7, Contacts) to determine whether a final survivor payment is due.

B: Notice of Reclamation

The Notice of Reclamation (FS Form 133) initiates the recovery of post-death benefit payments that 

have not been returned to the government, for which the RDFI may be liable.

The Notice of Reclamation is mailed or emailed to the RDFI by the government disbursing office 

upon instructions from the authorizing federal agency. The RDFI’s address and routing number are 

derived from the FOMF maintained by Treasury. Each RDFI is responsible for updating the FRB ACD 

(see Chapter 2, FOMF). RDFIs should also provide updated email addresses as needed, to ensure 

the timely receipt of Notices of Reclamation sent electronically.

Note: If the full amount listed on the reclamation is returned to the Disbursing Office, the RDFI does 

NOT need to complete and return the FS Form 133.

Table 3-A: Notice of Reclamation (FS Form 133)

The Notice of Reclamation advises the RDFI of the following:

x the date of death or legal incapacity,

x the amount of post-death benefit payment(s) for which the RDFI may be liable, and

x the identity of each benefit payment in question, including:

1. name of the recipient,

2. individual ID or claim #,

3. reclamation ticket #,

4. date of the payment(s),

5. Federal agency that authorized the payment(s) 

and the type of payment(s),

6. payment trace number(s),

7. type of account (checking/savings) to which the 

payment(s) was made,

8. depositor account number, and

9. amount of the payment(s).

The FS Form 133 consists of six parts (RDFI will receive Parts 1 through 5):

x Part 1- Program Agency Copy,

x Part 2- Program Agency File Copy,

x Part 3- RDFI Copy,

x Part 4- Disbursing Office Copy,

x Part 5- Notice to Account Owners Copy, and

x Part 6- Disbursing Office Pending Copy (RDFI 

does not receive Part 6).

Note: The reclamation ticket number is located in the top right box of the form to the right of the date 

(see sample FS Form 133). It is important the RDFI retains a copy of the reclamation form submitted 

via ARPS for a minimum of three years or until the associated case is closed. The RDFI should file the

notice using the reclamation ticket number. In the event that a debit is processed, the RDFI will need to 

locate the Notice of Reclamation using the ticket number provided on the FRB Statement of Account

(see How to Identify Debits using the Reclamation Ticket Number).

Sample of Notice of Reclamation (FS Form 133)

A sample of the Notice of Reclamation form (FS Form 133) is available in Chapter 9, Forms. The 

sample is the same for the Program Agency Copy, Program Agency File Copy, RDFI Copy and 

Disbursing Office Copy.
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5-10 A Guide to Federal Government ACH Payments

Table 3-B: How to Respond to the Notice of Reclamation

Steps to take Under Limited Liability

1. If funds are available, but not sufficient to satisfy the full reclamation, a partial payment should be 

remitted to the government disbursing office that issued the reclamation. When returning less 

than the full amount, the RDFI must authorize a debit by using the Automated Reclamation 

Processing System (ARPS) located in Treasury’s Pay.gov web portal.

2. Promptly mail the notice to the account owners * last known address(es) and notify the account 

owner(s) of any action that the RDFI has taken or plans to take against the account.

3. When the RDFI is returning less than the outstanding total listed on the Notice of Reclamation, 

the RDFI must complete and sign Certification No. 1*** and if the RDFI had no knowledge of the 

death at the time the benefit payment(s) was received or withdrawn, also sign Certification No. 

2  on the back of the Disbursing Office copy of the Notice of Reclamation. The RDFI must 

provide name, address and phone number of persons who withdrew from the account or if it is a 

sole owner account the RDFI MUST complete all applicable fields in ARPS when limiting their 

liability or retuning less than the total amount.

4. If the outstanding total**  was previously repaid to the federal government. The RDFI's obligation 

to the federal government (e.g., by the beneficiary's survivor) has been satisfied and the RDFI 

must return the Notice of Reclamation, attaching proof of the repayment, so that it is received by 

the government disbursing office within 60 calendar days of the date on the Notice. (See Types

of Evidence).

5. The signature in Certification No. 1*** and 2**** must be completed. The original signature 

must include the signer's first name and last name. The signer's title and phone number must 

be provided. If the Notice of Reclamation is incorrect due to error in fact or date of death, (see 

Learning of an Error).

* Some withdrawers may wish to restore all or part of the withdrawn post-death benefit payments to the 

account upon receipt of a Notice of Reclamation to Account Owners. Repayment to the account by the 

withdrawer upon receipt of the Notice of Reclamation is not required or requested by the government.

** The Outstanding Total is the sum of all federal benefit payments received after death or legal incapacity, 

minus any amount returned to or recovered by the government.

*** Certification No. 1 on the back of the Disbursing Office copy of the Notice of Reclamation certifies that: the 

Notice to Account Owners was sent; account owners were notified of any action the RDFI has taken or plans 

to take against the account; and the RDFI took proper corrective action regarding any error in date of or 

fact of death.

**** Certification No. 2 on the back of the Disbursing Office copy of the Notice of Reclamation, certifies that the RDFI 

had no actual or constructive knowledge of the death at the time of deposit or withdrawal of any of the post-death

benefit payments; and, that the RDFI has returned the amount of the account balance to the government.
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A Guide to Federal Government ACH Payments 5-11

ACH Debit

ACH Debit Authorization provided via Pay.gov permits Treasury to debit a financial institution’s 

Federal Reserve account. A payment made by ACH debit will appear on the financial institution’s 

Federal Reserve statement with an IAS transaction code of “57180 – Treasury ACH Reclamation FI

Auth”. There will also be a reclamation tracking number listed, which will aid a financial institution 

when researching debit transactions. ACH debits are received the same day and are posted within 

one (1) to two (2) business days of receipt.

Automated Reclamation Processing System (ARPS):

The Bureau of Fiscal Service has developed an electronic version of the current FS-133 process. This 

process allows financial institutions to submit a response to the Notice of Reclamation (NOR) 

electronically through the Department of the Treasury’s Pay.gov web portal. 

How to electronically respond to an ACH Reclamation:

Electronic responses should be made through Pay.gov, a web-based application operated by the 

Department of the Treasury that allows users to submit responses to a Notice of Reclamation. It also 

allows the Financial Institution to make payments to government agencies by electronic means by 

authorizing a debit. 

1. When the FMS 133, Notice of Reclamation is received, the financial institution will continue to 

follow its current procedures as stated in the Green Book (Chapter 5, Section 3, Reclamation 

Procedures)

2. Once the FI is prepared to respond to the Notice of Reclamation; this response will be submitted 

through the Pay.Gov web portal. This electronic version of the form requires the same information 

as the paper version.

3. Responding through Pay.gov allows the financial institution to limit liability as well submit full or 

partial payment(s) via a debit authorization. 

Incomplete or Inadequate RDFI Replies

If the RDFI’s response is inadequate, the government will send the RDFI a rejection via email,

indicating the reason for the disapproval. If no adequate response is received from the RDFI within 

the allotted timeframe, the government will initiate a debit action for the outstanding amount. 
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Time Limits for Federal Reclamations

1. INITIATION OF RECLAMATION (120-Day Protest): The authorizing federal agency must initiate the 

reclamation within 120 calendar days after the date that the agency first has actual or constructive 

knowledge of the death or legal incapacity of a benefit recipient or the death of a beneficiary.

An RDFI has the right to protest a Notice of Reclamation if it believes the agency did not meet the 

deadline for initiating the reclamation. 

A 120-day protest is filed by checking the appropriate box on the electronic form 133 in Automated 

Reclamation Processing System (ARPS). 

Upon receipt of the protest, the Fiscal Service will work with the authorizing federal agency to determine 

whether or not the agency met the 120-day deadline. If the RDFI’s protest is valid, then the RDFI will be

notified via email within 45 days and the reclamation action will be withdrawn. If the protest is denied,

and the RDFI qualifies for limited liability, the Disbursing Office will notify the RDFI via email within 45 

days and the RDFI will only be debited for the ACH 45-day amount. 

2. SCOPE OF RECLAMATION: An RDFI is not liable for any post-death benefit 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)]

3. COINCIDING WITH DATE OF DEATH: An RDFI is not liable for any benefit payment dated where 

as the effective date is the same as the date of death.

4. 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 calendar 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 FRB account or the account of its correspondent for the total amount of

the reclamation. This debit action will be final.

Follow-up to the Notice of Reclamation (Fiscal Service-2942)

A Follow-Up Notice is sent if the government disbursing office does not receive a response within 

30 days of the FS Form 133, Notice of Reclamation; or if the RDFI’s response to the Notice of 

Reclamation was incomplete or inaccurate.

A Follow-Up Notice is a reminder to the RDFI that a response to the Notice of Reclamation (FS Form 

133) must be received by the government disbursing office within 30 days of the date of the 

Follow-Up Notice, or the RDFI will forfeit the right to limit its liability. The Follow-Up to the Notice 

of Reclamation Form (FS Form 2942) is available in Chapter 9, Forms.

A copy of the original Notice of Reclamation is attached to the Follow-Up Notice

Responses to a Follow-Up Notice must be completed in ARPS (except for approved exceptions) in the 

same manner as an original Notice of Reclamation.

Any questions regarding this matter should be directed to the government disbursing office shown 

in the upper right corner of the Notice of Reclamation.

.
Green Book 5. Reclamations

A Guide to Federal Government ACH Payments 5-13

Federal Agency Collection from Withdrawers

If all or part of the post-death benefit payments have been withdrawn from the account before the 

RDFI learns of the death, and the RDFI properly responds to the Notice of Reclamation and is 

qualified to limit its liability, then the Reclamation process will be temporarily suspended, and the 

authorizing federal agency will attempt to collect the outstanding total from the withdrawer(s).

If the authorizing federal agency is unsuccessful in collecting the outstanding total from the 

withdrawer(s), the RDFI or its correspondent’s FRB account will be debited (for the ACH 45-day 

amount) not to exceed the outstanding total.

Debit of the RDFI’s Account

If the RDFI fails to respond completely and accurately to a Notice of Reclamation by the due date, 

the government disbursing office will debit the RDFI’s FRB account or that of its correspondent 

account for the full amount of its outstanding liability. This action is final.

If the RDFI responds completely and accurately to a Notice of Reclamation by the due date, and the 

federal agency is unable to collect the balance on the FS Form 133, the RDFI will be debited for the 

limited liability ACH 45-day amount.

The table below shows when the authorizing federal agency can exercise its authority to have an 

RDFI’s FRB account debited.

Table 3-C: Debit of the RDFI’s Account

If the RDFI: Then the RDFI (or its correspondent's) FRB Account

Fails to respond accurately and completely to 

the Notice of Reclamation.

Fails to respond within the 60-day time limit of 

the Notice of Reclamation.

Responds accurately, completely, and timely, 

(i.e., limited its liability) but the authorizing 

federal agency can no longer collect the 

outstanding total from the withdrawers.

will be debited for the outstanding total.

will be debited for the ACH 45-day amount not to exceed the 

outstanding total.
5. Reclamations Green Book

5-14 A Guide to Federal Government ACH Payments

 How to Identify Debits using the Reclamation Ticket Number

When there is a liability for an ACH reclamation payment by an RDFI, the RDFI will receive a charge 

to their FRB account. The reclamation ticket number will appear on the FI’s Statement of Account. 

This ticket number is the same number as identified on the original FS Form 133, Notice of 

Reclamation.

The FS Form 133, Notice of Reclamation form provides the reclamation ticket number in the top 

right box of the form to the right of the date. This ticket number should be used to identify debits 

for reclamations. Coordination between the ACH reclamation area and the RDFI accounting

department is critical to the reconcilement of the RDFI’s Statement of Account.

Provided below is an example of how the debit for ACH reclamations will appear on an FRB 

Statement of Account:

Explanation of the Debit:

1) The number 9914 indicates an entry processed by FRB Philadelphia to an out of district bank,

2) The phone number of the payment center that initiated the debit will be provided - e.g., (510) 594-7183.

The phone number is also provided in the upper right-hand corner of the reclamation notice,

3) The number 57170 is the transaction code representing an automated debit on ACH reclamations from 

the National Payment Center of Excellence (NPCE).is transaction code number will be unique for each 

RFC (See Table 3-D),

4) The number 03884 represents a batch number,

5) The number 7502 represents a reference number,

6) The number 051000033 is the FRB Philadelphia routing number,

7) The number 21234456 is the Reclamation Ticket number. This will be unique for each reclamation and 

is the same number as assigned on the original Notice of Reclamation form (FS Form 133), and

8) The dollar amount of the debit is indicated in the far-right hand column- e.g., 500.00.

Table 3-D: Transaction Codes for ACH Reclamations

The table below shows the unique transaction codes numbers for each Fiscal Service Portfolios.

Transaction 

Code\Description

Definition Daylight Overdraft

Posting Times

57170

Treas ACH REC Auto

Debits for reclamation payments authorized by the Treasury 

to post to a financial institution. These payments are

After close of 

Fedwire
Green Book 5. Reclamations

A Guide to Federal Government ACH Payments 5-15

57190

Treas ACH REC Auto

initiated to FRB Philadelphia by the Kansas City Federal

Disbursement Services Includes adjustments to such 

entries.

Debits for reclamation payments authorized by the Treasury 

to post to a financial Institution. These reclamation debits 

are initiated to FRB Philadelphia by the Modernization, 

Innovation, and Payment Resolution. Includes adjustments 

to such entries.

After close of 

Fedwire

C: Errors in Death

If the Person did not Die

If the RDFI obtains satisfactory proof that the benefit recipient or beneficiary is alive, the RDFI is 

still required to respond to the Notice of Reclamation in the Automated Reclamation Processing 

System. Failure to respond to the Notice of Reclamation will result in a debit to the RDFI or its 

correspondent’s FRB account for the outstanding total. In this case, a debit can only be restored 

after a verification process by the authorizing federal agency.

Types of Evidence

The following are acceptable types of proof for verifying that the person did not die:

x Driver’s license, picture ID or other evidence similar to that required for cashing a check, if the 

recipient or beneficiary appears at the RDFI,

x A signed, dated, and notarized statement attesting to the fact that the recipient or beneficiary is 

alive if, he/she is unable to appear at the RDFI, and

x A written statement from the authorizing federal agency verifying that the recipient or 

beneficiary is alive.

The RDFI is not obligated to accept the proof or to contact the authorizing federal agency if any 

disagreements or questions arise with the person presenting the proof. Prudence is required, as the 

action taken by the RDFI may impact its liability. Disagreements will be adjudicated by the

authorizing federal agency after it has been contacted by the person presenting the proof.

Note: If a Financial Institution needs to correct errors in their use of reason codes when returning 

funds, they should contact the agency receiving the return. Please see Chapter 7, Contacts, for major 

paying agency contact information.

Table 3-E: Accepting the Proof

The table below shows what actions the RDFI must take if it accepts the proof that the person did 

not die.

Step Action

1. Within ARPS, select payee alive.

2. Digitally sign Certification #1 and Certification #2.

3. A signed, dated notarized statement attesting the fact that the payee is alive

 DNE removal request

4. Written letter from agency (which we will confirm) stating payee is alive.
5. Reclamations Green Book

5-16 A Guide to Federal Government ACH Payments

5. Advise the recipient to contact the authorizing federal agency to restart payments.

Table 3-F: Rejecting the Proof

The table below shows the actions the RDFI must take if it rejects the proof that the person did not 

die.

Step Action

1. Continue to process the Notice of Reclamation, which includes sending the Notice of Reclamation to 

account owner(s).

2. Refer the person presenting the proof to the federal agency.

3. Notify the account owner(s) to provide a written statement from the federal agency verifying that the 

recipient or beneficiary is alive, or the reclamation process will continue.

Restarting Payments

Once a reclamation has been processed, all further benefit payments will be stopped. Presenting 

acceptable proof that the death report was in error (and stopping the reclamation process) does 

not restart the monthly benefit payments. The recipient or beneficiary must contact the authorizing 

federal agency to re-enroll in Direct Deposit.

If the Date of Death is Wrong

The RDFI is authorized to adjust the outstanding total, provided it obtains acceptable proof that the 

date of death (DOD) shown on the Notice of Reclamation is wrong. When correcting a date of death 

error, the RDFI should always check the appropriate box in ARPS, provide the correct DOD and 

submit a death certificate via email to PFC-reclamations@fiscal.treasury.gov

Learning of an Error After Completing a Reclamation

If the RDFI learns of an error in the date of death after returning a completed Notice of Reclamation 

and it has already satisfied its liability, it MUST contact the authorizing federal agency (based on the 

payment type listed on the Notice of Reclamation) to make the appropriate adjustment.

If the RDFI is due a refund, the RDFI must provide supporting documentation to the authorizing 

federal agency.

Note: Only the authorizing federal agency can make adjustments after the debit action has been 

processed.
A Guide to Federal Government ACH Payments 5-17

Green Book 5. Reclamations

Table 3-G: Worksheet for Adjusting the Outstanding Total if the Date of Death is Wrong

The worksheet below may be used by the RDFI to calculate the adjusted total if there is an error in the 

date of death.

PMT 1 PMT 2 PMT 3 PMT 4

List the month/day/year of each payment shown on the 

Reclamation form.

For each payment (shown on the Reclamation) did the person die 

before the date of the payment? (Enter "yes" or "no")

For each "yes", enter the dollar amount of the payment.

(Do not enter the dollar amount if "no.")

Total all "yes" payments $ 

(This is the adjusted outstanding total to use on the Notice of Reclamation).

D: Subsequent Notice of Reclamation

The government may issue a subsequent Notice of Reclamation if the original Notice of Reclamation 

did not list all post-death benefit payments.

A subsequent Reclamation may be issued if any of the following apply; the date of death was earlier than 

shown on the original Notice of Reclamation, the account number changed, and/or the routing number 

changed.

What to do if the RDFI receives a subsequent reclamation.

An RDFI receiving a subsequent Notice of Reclamation should respond as the RDFI would respond to an original 

Notice of Reclamation.”

Previous debit

If the RDFI has already limited its liability and has been debited for the ACH 45-day amount on the 

original reclamation case, it will not be debited again on a subsequent Reclamation for the same case. 

However, in order to maintain its limited liability status, the RDFI must respond to all Notice of 

Reclamations received to prevent a debit to the RDFI or its correspondent’s FRB account.

 E: Contacts

For Pay.gov technical issues please contact: 800-624-1373 (Toll free, Option #2), 216-579-2112 

(Option #2), pay.gov.clev@clev.frb.org, Hours 8:00am to 7:00pm Monday – Friday. 

For questions related to a Notice of Reclamation or general Notice of Reclamation inquiries, please 

contact: (855) 868-0151

Any supporting documentation related to the Notice of Reclamation response (payee alive, incorrect 

date of death, etc.) must be emailed to PFC-Reclamations@fiscal.treasury.gov within 15 business days.