For those using Yellow Hammer Fraud Detective, do you use the ACH Beneficiary Does Not Match CIF rule to identify federal government payments that are not in the name of the account holder? If you do, have you had issues with customers spending the funds before the item is worked in fraud the following day? How does the bank handle those overdrafts? If you do not use this rule, have you had any criticism during exams or audits for not using this tool to identify those transactions?
I wish all of the FINTECHs would read this guide issued by FDiTech in conjunction with the FDIC. Perhaps if more FINTECHs would become aware of FI needs, requirements, and compliance considerations, when I ask for certain due diligence materials I might not get the response, "Well, I have never had anyone ask me for that before." That tired old answer from FINTECHs worn out. I may attach a copy of this guide to future RFPs.