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Build a daily review for positive-pay check exceptions

Give check exceptions an owner, a decision deadline and an evidence trail so legitimate payments are handled without approving altered items.

By Institution3 minute readPublished View sources
In this guide

Understand the decision the bank expects

A positive-pay exception needs a decision under the bank's service terms. Establish what data the service compares, where exceptions appear, when responses are due and what happens if nobody responds. Ask whether payee matching is included and how the bank handles missing issue records, changed amounts and other mismatches. Keep the actual contract or service instructions with the procedure.

The FBI recommends check positive pay where available as a fraud-prevention measure. Bank services differ: Chase, for example, publishes product-specific eligibility and exception handling. Use the instructions for the company's own account instead of borrowing another bank's deadline or assuming that every service returns unanswered items.

References: FBI: Mail theft and check fraud prevention; Chase: Business fraud-protection services

Put the issue file under the same discipline as the payment run

Reconcile issued checks with the file delivered to the bank. Confirm the upload acknowledgment and retain the accepted count and total where the service provides them. A missing issue record may cause a legitimate check to appear as an exception. Fix the transmission problem without treating every future mismatch as harmless.

Include voided and replacement checks in the process. Decide who updates the bank after an accounting user voids a check, and confirm whether the software sends that update automatically. When a batch is rejected, resolve the rejection before assuming the bank knows which checks the company issued.

Review the image against independent records

Compare the presented item with the approved payment, original payee and amount. Examine the bank image where available and investigate any unexplained alteration. If the check appears unfamiliar, contact the payment owner through the company's established directory. Do not rely on contact information printed in an unexpected email requesting urgent approval.

A useful review record captures the exception reference, evidence examined, decision, reviewer and response time. Avoid writing only approved. Another person should be able to understand why the presented item was consistent with the company's instruction.

When evidence is insufficient, follow the bank's escalation process before the response deadline. Involve the authorized treasury or finance lead. Do not approve an uncertain item solely to avoid inconveniencing a supplier; a payment problem can be investigated with the supplier using a verified contact.

Provide coverage when the normal reviewer is absent

Assign a primary reviewer and a separately authorized backup. Confirm that both can access the exception queue and receive alerts through their own credentials. A shared password makes responsibility harder to establish and can fail when authentication depends on an absent employee's device.

Build the review into the working day with the bank's time zone and cutoff clearly stated. Check holiday coverage and staff absences. If the business does not issue checks regularly, retain the review responsibility while old checks remain outstanding; activity can occur after the latest payment run.

Tie decisions back to the reconciliation

Match accepted items to cleared checks and follow returned items to their next action. A supplier may need a corrected or replacement payment, while suspected fraud requires separate escalation. Keep those outcomes visible in the outstanding-check register so the accounting team does not repeatedly investigate a decision already made by treasury.

Review recurring exception reasons monthly. Frequent missing files suggest a submission problem; repeated payee mismatches may require a closer look at issue data or the bank's comparison rules. Use the pattern to improve the process while retaining individual review of unexplained checks.

Sources

Requirements and product details can change. Check the linked guidance for the facts that apply to your situation.

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General information, not personalized accounting, tax, legal, or investment advice. Have the appropriate qualified professional review decisions that depend on your circumstances.