TN 25 (05-91)
SI 01130.700 Identifying Excluded Funds That Have Been Commingled With Nonexcluded Funds
A. POLICY PRINCIPLE
Otherwise excludable funds must be identifiable in order to be excluded.
B. OPERATING POLICY
1. Identifiable vs. Segregated
Identifiability does not require that excluded funds be kept physically apart from other funds (e.g., in a separate bank account).
2. Operating Assumption
Always assume, when withdrawals are made from an account with commingled funds in it, that nonexcluded funds are withdrawn first, leaving as much of the excluded funds in the account as possible.
3. Effect Of Account Transactions
If excluded funds are withdrawn, the excluded funds left in the account can be added to only by:
If interest on the excluded funds is excluded (as with disaster assistance), the percent of an interest payment to be excluded is the same as the percent of funds in the account that is excluded at the time the interest is posted. The excluded interest is then added to the excluded funds in the account.
C. DEVELOPMENT AND DOCUMENTATION — INITIAL CLAIMS AND POSTELIGIBILITY
Obtain a complete history of account transactions back to the initial deposit of excluded funds. Use the individual's own records if possible.
Accept the individual's allegation as to the date and amount of a deposit of excluded funds if it agrees with the evidence in file on the receipt of the funds.
Record on an RC (or with a computer printout):
each deposit of excluded funds;
each withdrawal that reduces the amount of excluded funds;
each computation of excluded interest and its addition to the excluded funds.
1. One-Time Receipt And Deposit Of Excluded Funds
An individual deposits a $1,000 SSI check ($800 for the preceeding 4 months and $200 for the current month) in a checking account. The account already contains $300 in nonexcluded funds.
Of the new $1,300 balance, $800 is excluded as retroactive SSI benefits.
The individual withdraws $300. The remaining $1,000 balance still contains the excluded $800.
The individual withdraws another $300, leaving a balance of $700. All $700 is excluded.
The individual deposits $500,creating a new balance of $1,200. Only $700 of the new balance is excluded.
2. Periodic Receipt And Deposit Of Excluded Funds
An individual deposits $200 in excluded funds in a non-interest bearing checking account that already contains $300 in nonexcluded funds.
The individual withdraws $400. The remaining $100 is excluded.
The individual then deposits $100 in nonexcluded funds. Of the resulting $200 balance, $100 is excluded.
The individual next deposits $100 in excludable funds. Of the new $300 balance, $200 is excluded.
A $1,000 savings account includes $800 in excluded disaster assistance when a $10 interest payment is posted. Since 80 percent of the account balance is excluded at the time the interest is posted, 80 percent of the interest ($8) is excluded. The amount of excluded funds now in the account is $808.