IRS Provides Update on EIP Program


The Internal Revenue Service (IRS) provided an update on the first four weeks of the Economic Impact Payment (EIP) program progress and advised that individuals who are incarcerated, non-resident aliens, or who died before the payment was received are not entitled to the Payments.

The payment figures released by the Treasury and IRS show that during the first four weeks of the program, approximately 130 million individuals received payments worth more than $200 billion. Regionally, over 5 million payments were issued worth almost $9 billion.

  • Idaho
    672,496 payments
  • Oregon
    1,658,586 payments
  • Washington
    2,856,962 payments

The IRS also updated the Economic Impact Payment Information Center with instructions for returning Economic Impact Payments, as well as information regarding payments that were sent to deceased, incarcerated, or non-resident aliens.

  • Does someone who has died qualify for the Payment?
    • No. A Payment made to someone who died before receipt of the Payment should be returned to the IRS by following the instructions in the Q&A about repayments. Return the entire Payment unless the Payment was made to joint filers and one spouse had not died before receipt of the Payment, in which case, you only need to return the portion of the Payment made on account of the decedent. This amount will be $1,200 unless adjusted gross income exceeded $150,000.
  • Does someone who is a resident alien qualify for the Payment?  
    • A person who is a non-resident alien in 2020 is not eligible for the Payment. A person who is a qualifying resident alien with a valid SSN is eligible for the Payment only if he or she is a qualifying resident alien in 2020 and could not be claimed as a dependent of another taxpayer for 2020. Aliens who received a Payment but are not qualifying resident aliens for 2020 should return the Payment to the IRS by following the instructions about repayments.
  • Does someone who is incarcerated qualify for the Payment?  
    • No. A Payment made to someone who is incarcerated should be returned to the IRS by following the instructions about repayments. A person is incarcerated if he or she is described in one or more of clauses (i) through (v) of Section 202(x)(1)(A) of the Social Security Act (42 U.S.C. § 402(x)(1)(A)(i) through (v)). For a Payment made with respect to a joint return where only one spouse is incarcerated, you only need to return the portion of the Payment made on account of the incarcerated spouse. This amount will be $1,200 unless adjusted gross income exceeded $150,000.

NACHA has updated their FAQ regarding how an RDFI should handle an EIP to the account of a customer that is deceased, incarcerated, or a non-resident alien.

Question of the Week

Q. Our member lost his ATM card sometime in the last 10 days. There have been several unauthorized transactions on his account. He wrote his PIN on the back of the card. Do we have to credit his account with the money, even though he was negligent?

A. Unfortunately, Reg E does not have a provision for consumer negligence, even if the PIN was written on the card. If a member reports a card lost or stolen within two business days of learning of the loss or theft, the member is liable for a maximum of $50. The liability can increase to $500 if the loss is reported after two business days. The member may have additional liability if the loss or theft goes unreported, and the member does not report the unauthorized activity within 60 days of receiving their periodic statement.

Related Links

12 CFR 1005.6
Reg E Official Interpretations

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Questions? Contact the Compliance Hotline: 1.800.546.4465;

Posted in Compliance News, Compliance News.