SSA - POMS: SI 01140.200 - Checking and Savings Accounts

A. Introduction to checking and savings accounts verification

The Access to Financial Institutions (AFI) initiative is now operational for Supplemental Security Income (SSI) eligibility and waiver purposes in all 50 states, the District of Columbia, and the Northern Mariana Islands. The two main components used in the AFI process are the:

1.

eAFI subsystem, and
2.

e4641 website.

The eAFI process uses the eAFI subsystem in the SSI Claims system and the e4641 website to automatically request and view bank account balance data to help reduce payment errors related to financial accounts. Electronic verification is the preferred method to verify checking and savings accounts. For specific instructions for AFI, see SI 01140.206.

B. Policy for developing checking and savings accounts

1. Assumptions related to checking and savings accounts

Use the following assumptions when evaluating whether checking or savings accounts meet the general definition of a resource found in SI 01110.100.

NOTE: Consider whether evidence that the account is not a resource exists as provided in SI 01140.200B.2 in this section.

a. Account ownership

Assume that the person designated as owner in the account title owns all the funds in the account. For information about joint accounts, see Joint Checking and Savings Accounts SI 01140.205.

b. Right to withdraw funds

Assume that the person shown as owner in the account title has the legal right to withdraw funds from the account.

c. Right to use for support and maintenance

Assume that individuals who own and have the legal right to withdraw funds from a bank account also have the legal right to use them for their own support and maintenance.

d. Conservatorship accounts

If State law specifically requires that funds are available for the care and maintenance of an individual, assume, absent evidence to the contrary, that they are that individual's resource. This is true despite the fact that the individual or agent may have to petition the court to withdraw funds for the individual's care. Refer to any regional instructions regarding State law on “blocked or conservatorship accounts,” per SI 01140.215.

e. Fiduciaries

Assume a fiduciary's right to withdraw funds is the same as the owner's right to withdraw them. See SI 01120.020 for information on transactions involving agents.

f. Direct Deposit

A direct deposit indicator on the Supplemental Security Record or Master Beneficiary Record indicates a need to develop for financial account(s). After development, if appropriate, record the financial account used for direct deposit (including Direct Express or similar accounts) as a resource on the Financial Accounts screen in Consolidated Claims Experience.

2. Factors that may preclude a checking or savings account from meeting the definition of a resource

A checking or savings account does not meet the definition of a resource if the account owner does not have the legal right to withdraw funds from the account or is otherwise restricted from using the funds. For more information on the definition of a resource, see SI 01110.100.

The following are examples of limitations that may preclude a checking or savings account from meeting the definition of a resource.

a. Example of the right to withdraw funds restricted to a specified account holder

A bank account might not be a resource if the account restricts the right to withdraw funds from the account to a specific account holder. For example, the account titled “In trust for John Doe and Jane Doe, subject to sole order of John Doe, balance at death of either to belong to survivor” is a restricted account. The title indicates that John alone has unrestricted access. Assuming that no other separate agreement establishes John as Jane's fiduciary and that John is not a deemor, none of the funds in this account are Jane's resources.

b. Example of withdrawals requiring authorization of third party

A bank account might not be a resource if withdrawals from the account require authorization from a third party.

For example, the title on the account is, “John Doe restricted Individual Indian Money Account.” John Doe’s account is a restricted and supervised Individual Indian Money Account (IIM). The funds in the account are not countable as a resource because John Doe cannot withdraw the funds without the authorization of the Bureau of Indian Affairs (BIA). For more information on Individual Indian Money Accounts, see SI 00830.820.

c. Example of use restricted by court order

Even with ownership interest and the legal ability to access property, a legal restriction against the property's use for the owner's own support and maintenance means the property is not the owner's resource. For more information on the distinction between assets and resources, see SI 01110.100.

For example, the title of the account is, “John Smith by Jane Doe, Representative Payee,” where Jane Doe is an officer of the institution in which John Smith lives. A statewide court order prohibits such officers from using the funds of an institutionalized person for support and maintenance that the State provided. Therefore, the funds in the account are not a resource to John Smith while they are in the institution.

d. Example of special purpose accounts

The title of the account is, “Johnny Johnson, Kiwanis Club Fund for Heart Surgery.” While Johnny Johnson has unrestricted access to the funds, the title on the account should prompt further development. In this example, that development shows that the account restricts the use of funds to the expenses of their surgery. Therefore, the funds are not a resource.

e. Example of payable on death accounts

A Payable on Death (POD) account is a financial instrument in which an account owner establishes a beneficiary to whom the bank will transfer remaining account funds upon the account owner's death. While the account owner is alive, the POD beneficiary has no legal right to the funds and the account is not the beneficiary's resource.

For example, the title of the account is, “John Doe, POD Jane Doe.” Assuming that John is not a deemor, the funds in this account are not a resource for Jane while John is alive.

C. Procedure for verifying financial institutions (FI) accounts

1. Request account balances from the financial institution

The request type to verify financial account balances depends on whether the FI is participating or nonparticipating. For more information on participating and non-participating FIs, see SI 01140.206B.7.

a. Send an electronic request

Send an electronic request to verify financial account balances held in participating FIs.

To prepare and send an electronic request for SSI Claims system cases, follow procedure in SI 01140.206E. For non-SSI Claims system or systems limitation cases, see SI 01140.206F.

b. Mail or fax a paper SSA-4641

Mail or fax a paper SSA-4641 (Authorization for the Social Security Administration to Obtain Account Records from a Financial Institution and Request for Records) to non-participating FIs to verify alleged financial accounts held in these FIs.

To prepare an SSA-4641, follow procedure in SI 01140.206E.1.b.

c. FI responses for waiver requests

Financial information is also used to make determinations on whether denying a waiver would “defeat the purpose” of the Social Security Act. Information obtained in making that determination can be used in making determinations on SSI eligibility.

Use account balance information associated with a waiver request to verify accounts balances for any applicable unverified months in the Financial Institution Account resource page where financial permission is present. If any Geographic search requests associated with a waiver request produce undisclosed accounts, develop the accounts per SI 01140.206H.3.

For waivers related to the defeat the purpose of the Supplemental Security Income (SSI) program, see GN 02250.100.

For information on financial permission, see SI 00515.001.

2. Use the individual’s bank statements, FI records, or allegation to verify FI accounts

Electronic verification is the preferred method to verify FI accounts. However, in certain situations, you may have to request FI information from the individual. An individual may provide bank statements, FI records, or provide a signed statement as evidence. To request evidence, follow procedure in SI 00601.100.

The following are situations where you may accept the individual’s bank statements, FI records, or allegation as evidence of the account balances and adjudicate the claim event.

a. Accept the individual’s bank statements

Accept the individual’s bank statements as evidence and adjudicate the event when they provide all bank statements that cover the verification period in question.

For more information on determining the verification period, see SI 01140.206D.

To determine the first of the month balances using bank statements, see SI 01140.200D.6.a. and SI 01140.200G in this section.

b. Accept the individual’s bank statements or FI records

Accept the individual’s bank statements or FI records as evidence and adjudicate the event when:

•

The FI has not responded within 15 days of sending a verification request using eAFI or e4641.
•

The FI incompletely responded to a verification request. For example, the verification request included 20 months of balance data, but the FI responded with only 5 months of balance data.
•

The verification request pertains to an initial claim designated as a terminal (TERI) case.
•

The only alleged FI account is a collective account. To document collective accounts in the Financial Institution Account page, follow instructions in SI 01140.206C.7.
•

The only alleged FI account is a foreign FI account located outside the country and the individual does not conduct banking business with a domestic sister branch. For more on the treatment of foreign accounts, see SI 01140.206C.8.

NOTE: FI records must meet certain criteria listed in SI 01140.200C.3. in this section.

c. Accept the individual’s allegation

If no other evidence is available, accept the individual’s allegation as evidence of bank account balances and adjudicate the event. Document the individual’s signed statement on an SSA-795 (Statement of Claimant or Other Person) or on the Person Statement screen in the SSI Claims system.

NOTE: Process as a stand-alone post-eligibility event any electronic responses received post-adjudicatively.

3. Which FI records to use

a. Acceptable FI records

The following are acceptable forms of FI records:

1.

FI original records that appear to be complete and unaltered.
2.
FI records other than bank statements issued by the FI, and where:
- •
  
  the individual alleges that no transactions have occurred that the records do not show; or
- •
  
  the individual alleges that such transactions have occurred and provides appropriate evidence of them; and
- •
  
  the records, the allegation regarding additional transactions, and the alleged current account balance (on the application or redetermination form) reflect a complete and consistent picture of the account.
3.

Alternatively, FI records that were verified using the telephone (see SI 01140.200E in this section).

b. Examples of FI records other than bank statements

Examples of other acceptable records include:

•

passbooks;
•

the individual’s check register;
•

bank statements or account activity information printed from the FI’s website and submitted by the individual;
•

account ledgers;
•

ATM transaction receipts; and
•

deposit or withdrawal slips.

4. Discovering a previously undeveloped FI account after eligibility has been established

If you discover a previously undeveloped checking or savings account after you establish eligibility, develop account balances and interest for the period that a determination can cover under the rules of administrative finality. For more information on administrative finality, see SI 04070.000.

If you find fraud or similar fault, see SI 04070.020.

5. Interest payments

Do not check block B.2 on page 4 of the SSA-4641 or the Interest checkbox when using the eAFI subsystem and e4641 website if SI 00830.500 does not require verification of interest amounts.

D. Procedures for initial claims and post-eligibility

1. Informing individuals of reporting responsibilities

Advise individuals of their reporting responsibilities as follows:

•

Individuals must report any bank account on which their name appears, regardless of any special purpose of the account or whose money is in it; and
•

We may use other statements or forms to obtain information from any bank or FI to verify the allegations.

2. Obtain the financial permission before verifying financial account balances

Determine whether the recipient or deemor has granted SSA permission to request financial account balance information per SI 00515.001. You must obtain a wet signature for a paper SSA-4641 (Authorization for the Social Security Administration to Obtain Account Records from a Financial Institution and Request for Records). For instructions on electronic financial institution verification, see SI 01140.206C.

3. Account balance information

The FI may show the opening balance for the first day of a given month or the closing balance for the last business day of the previous month. Accept either; the amount will be the same.

4. Curtailing development of account balances

Do not verify account balances under any of the following circumstances:

•

The tolerance for verifying liquid resources applies and the individual is not rebutting ownership of funds in a joint account. For the liquid resource tolerance, see SI 01140.010C. For joint accounts, see SI 01140.205C;
•

Advance filing applies; or
•

The individual alleges countable resources in excess of the resource limit, and is ineligible for or declines conditional benefits.

5. Documentation of FI accounts

In addition to the account balances, document all of the following on the Financial Institution Accounts page:

•

The name and address of the FI;
•

The account number(s); and
•

The exact account designation.

6. Resource exclusion for early payment deposits included in first of month balances

When an account balance is material to eligibility (i.e. first of the month balance is contributing to a determination of excess resources), determine whether the first of the month account balance includes an early SSI payment, State supplement, or any other regular income payment.

Review the case according to the following procedures if the amount of the early-deposited payment could be material to eligibility.

a. Early deposit of SSI payments and Federally-administered State supplements

Determine whether we issued the SSI payment and any applicable federally administered State supplement prior to the first of the month by reviewing the list of early deposit months found at SM 01315.005.

For each SSI EDB month, exclude the value of the SSI payment and any applicable federally administered State supplement from the account balance if all of the following are true:

•

The SSI payment is pertinent to determining eligibility because the recipient’s resources exceed the resource limit by an amount equal to or less than the SSI payment plus any applicable Federally administered State supplement;
•

The month is an early deposit month listed in SM 01315.005; and
•

The SSI payment and any applicable Federally-administered State supplement were direct deposited to the account, transferred into the account before the first of the month, or otherwise included in the first of the month resource balance.

Document this SSI EDB resource exclusion by recording the value of the SSI payment and any Federally-administered State supplement as the excluded amount on the Financial Institution Account resource page. Select the exclusion reason “Early RSDI or SSI payment”. For more information on the Financial Institution Account page, see MS 08113.017.

Note:

While direct deposit situations are the most common application of the EDB exclusion, direct deposit is not a requirement to exclude early payments. For example, early delivery of a payment check that is held as cash or subsequently deposited into an account is subject to the same exclusion if the early payment amount is included in the first of the month resource balance.

b. Recurring SSI payments included in first of month balances

Even in months when SSI is paid on the 1st of the month, an FI may include the SSI payment amount in the first of the month balance. To determine whether a recurring SSI payment is part of the first of the month balance, and whether you need to request additional evidence from the individual, consider whether:

•

The account balance is pertinent to determining eligibility;
•

The account balance exceeds the resource limit by an amount equal to or less than the SSI payment plus any applicable federally administered State supplement; and
•

The difference in the account balance could be attributable to the FI including the amount of an SSI payment in the first of the month balance. For example, recipients have their payment directly deposited, and the FI credits a recurring SSI payment on the day prior to the first of the month balance.

Document the early deposit resource exclusion by recording the value of the SSI payment and any Federally-administered State supplement as the excluded amount on the Financial Institution Account resource page. Select the exclusion reason “Early RSDI or SSI payment”. For more information on the Financial Institution Account page, see MS 08113.017.

c. Early deposit of State- administered State supplements

Many States administer their own State supplement programs and issue recurring payments. In contrast to Federally-administered supplements issued by SSA, payments under State-administered plans are not included in monthly SSI payments. If you become aware of an early-deposited State-administered supplementary payment amount that is included in the first of the month balance and is material to eligibility, take the following actions:

•

Ensure the State supplementary payment amount is documented on the Other State, Local, or Tribal Assistance page in the SSI Claims system and that any early-deposited benefit is shown as received in the month of normal receipt. For more information on the Other State, Local, or Tribal Assistance page, see MS 08114.019.
•

Use the 'Excluded Amount' column on the Financial Institution Account resource page to exclude the State-administered supplement amount from the reported first of the month resource balance in the month of normal receipt. For exclusion reason, select "Other" from the drop-down list and type in "early deposit of State Supplement payment."
•

Document the file with the allegation of the early deposit and actions taken to exclude the early payment from the first of the month resource balance using the file documentation notes section on the Financial Institution Account page in the SSI Claims system or a Report of Contact.

d. Early deposit of other recurring income

Be alert to situations in which other regular benefits or payments (e.g. Title II benefits, regular wages, etc.) are received outside of the month of normal receipt (i.e. normal receipt date falls on a weekend or holiday). If you become aware of an early-deposited payment that is included in the first of the month balance and is material to eligibility, take the following actions:

•

Develop and document the income by following the applicable policy for the income type.
•

Take action to count the income as received in the month of normal receipt.
•

Use the 'Excluded Amount' column on the Financial Institution Account resource page to exclude the payment from the reported first of the month resource balance in the month of normal receipt. For Title II benefits, select the exclusion reason “Early RSDI or SSI Payment.” For all other income types, select "Other" from the drop-down list and type in "early deposit of recurring payment."
•

Document the file with the reason the payment was received outside the normal payment schedule and the actions taken to apply the exclusion using the file documentation notes section on the Financial Institution Account page in the SSI claim system or on a Report of Contact.

For general information on when income is counted and how income and resource counting polices interact in early deposit situations, refer to SI 00810.030B and SI 01110.600B.3, respectively.

E. Procedure for verifying account balances with an FI using the telephone

Follow these instructions to verify account balances when using the telephone:

•

Use an automated customer service line to obtain account balances only if it provides complete transaction information, i.e., deposits, withdrawals, cleared checks, and transfers to and from the account along with transaction dates.
•

To be certain that you access the correct account, dial the bank's customer service line and enter the proper account numbers. However, if required to respond to security prompts, for privacy purposes have individuals enter their own security information (i.e. login ID, PINs or pass codes, etc.). Never ask the person to provide you with this information. If telephone verification would cause the individual's security information to be compromised (i.e. you are verifying via a three-way conference call and the automated line requires you to key in security information), stop and verify account information another way.
•

Examine all account activity to determine the account balance as of the first of the month.
•

The records do not have to specify a first of the month balance; they need only make it possible to extrapolate from before and after balances. For more information, see the examples in SI 01140.205G.
•

Be alert for payments for both direct deposit and payment by check situations that have an advance date.
•

Treat any payment made early because the payday falls on a holiday or weekend day as income for the month of normal receipt. For more information, see When Income is Counted in SI 00810.030B.

F. Procedure for income-related issues

1. Interest for income purposes

For information on the treatment of interest for income purposes, see Dividends and Interest SI 00830.500.

2. Unusual deposits

When a claimant or recipient provides bank statements or passbooks for documentation, review the supplied evidence for deposits that you cannot account for from their stated income. If deposits indicate undisclosed income sources, contact the individual to develop the income and follow the appropriate policy in SI 0810.000 to document the record.

For a definition of income, and when to count it, refer to SI 00810.005 and SI 00810.030, respectively.

G. Examples of verifying account balances

1. Extrapolating first of the month balances

A bank sends out checking account statements that cover the 10^th of one month through the 9^th of the next. The last transaction shown for April is a deposit that creates a $100 balance. The first transaction in May is a $50 withdrawal that leaves a $50 balance. This shows that May 1^st balance was $100.

Consider using other available evidence to confirm the account balance information. In the example above, the ATM withdrawal receipt from the first transaction in May can corroborate the remaining account balance, and confirm extrapolated first of the month balance.

2. Advance dated payments

The claims representative (CR) initiates a redetermination for a recipient on 05/10/20. The recipient alleges having the following resources:

•

Checking account balance $450.00;
•

Savings account balance $650.00;
•

Face value life insurance policy $1,000.00; and
•

Alleged countable liquid resources $1,100.00.

During the interview, the recipient provides bank statements covering the review period up to 04/15/20. To verify the first of the month balance for May 2020, the CS uses the bank’s automated customer account line. The CS identifies the deposits and withdrawals from 04/15/20 through 05/01/20 and notes that we direct-deposited the SSI check for May on 04/29/20.

The following table depicts the account activity and balance information for the savings account:

Savings
Date	Activity	Debits	Credits	Balance
04/15/20	balance			$550.00
04/30/20	transfer from checking		$100.00	$650.00
05/01/20	balance			$650.00

The following table depicts the account activity and balance information for the checking account:

Checking
Date	Activity	Debits	Credits	Balance
04/15/20	balance			$480.00
04/16/20	withdrawal	$50.00		$430.00
04/23/20	check #1165 cleared	$90.00		$340.00
04/23/20	withdrawal	$50.00		$290.00
04/26/20	check # 1164 cleared	$65.50		$224.50
04/30/20	withdrawal	$50.00		$174.50
04/30/20	check #1166 cleared	$72.00		$102.50
04/30/20	transfer to savings	$100.00		$2.50
04/29/20	deposit (SSI)		490.00	$492.50
05/01/20	balance			$492.50

Total verified countable resources 05/01/20: $652.50 ($650 in savings + $492.50 in checking = $1,142.50 - the SSI early deposit of $490.00).

Since the 04/29/20 deposit was an early deposit of the May SSI payment amount, the CS does not count it as a resource on 05/01/20. The CS also could have used the claimant’s checkbook and bank transaction summary receipts for payment and deposit information.

3. Allegation of check that has not cleared the bank

A claimant’s bank statement shows a checking account balance of $1,350 as of May 1^st, which combined with their other alleged countable resource exceeds $2,000 as of the first of the month. The claimant alleges that the statement balance includes a rent check of $500 written and given to their landlord on April 25^th, but that the landlord has not cashed the check yet.

The CS examines the claimant’s check register and finds an annotation for check number 1345 for $500 written on April 25^th. The CS also notes that check 1346 has already cleared the bank and the amount has been deducted from the claimants account on the bank statement. Next, the CS notes that the claimant has written a $500 check to their landlord for rent on the 25^th of each month for the last 6 months since the claimant moved into the apartment.

Since there is evidence that the claimant has written the check and legally obligated those funds in the account, and the records provide a complete and consistent picture of the account, the CS can deduct the amount of the uncashed check from the May 1^st of the month balance. The CS can deduct the uncashed check because SSI equity value rules state that in determining equity value, we deduct encumbrances from the current market value (CMV). The new balance of $850 permits resource eligibility.

4. Early SSI deposit

While verifying bank account balances during a redetermination, a CS discovers several months over the period of review in which the recipient’s account balances were higher than usual. Because the balances in many of these months caused an excess resources determination, the CS screens for early deposit months using the chart in SM 01315.005.

The early deposit months during the period of review were: 06/2019, 09/2019, 12/2019, 01/2020, 02/2020, and 03/2020.

In reviewing the SSR, the CS finds that the recipient received the full benefit rate in every month during the period of review.

The CS applies early deposit exclusions as follows:

Checking Account Balances

Date	Bank Account Balance	Total Resource Balance	Amount of SSI Deposit	Exclusion Applied	New Total Resource Balance
05/01/2019	$1,255.76	$1,255.76	$771.00		$1,255.76
06/01/2019	$2,035.30	$2,035.30	$771.00	$771.00	$1,264.30
07/01/2019	$1,280.54	$1,280.54	$771.00		$1,280.54
08/01/2019	$1,300.01	$1,300.01	$771.00		$1,300.01
09/01/2019	$1,961.86	$1,961.86	$771.00	$0*	$1,961.86
10/01/2019	$1,350.29	$1,350.29	$771.00		$1,350.29
11/01/2019	$1,402.50	$1,402.50	$771.00		$1,402.50
12/01/2019	$2,221.72	$2,221.72	$771.00	$771.00	$1,450.72
01/01/2020	$2,059.10	$2,059.10	$783.00	$783.00	$1,276.10
02/01/2020	$2,087.11	$2,087.11	$783.00	$783.00	$1,304.11
03/01/2020	$1,993.69	$1,993.69	$783.00	$0*	$1,993.69
04/01/2020	$1,308.83	$1,308.83	$783.00		$1,308.83

*Even though early deposit occurred in 9/2019 and 3/2020, the total resource value was under the $2,000 resource limit. In these months, applying the early deposit exclusion is not necessary. We only develop the exclusion when the early deposit amount affects eligibility. You do not need to record an amount in the "Excluded Amount" field on the Financial Institution Account page for these months.

H. References

•

FMM 03.05.12 Financial Management/Finance and Accounting Manual
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SI 00810.030—When Income is Counted
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SI 01110.600—First-of-the-Month (FOM) Rule for Making Resource Determinations
•

SI 01140.206--Electronic Financial Institution Verification
•

SM 01315.005--SSI Early Payment Date Information and Schedule

Program Operations Manual System (POMS)

SI 01140.200 Checking and Savings Accounts