How should deposits from stimulus checks be treated?

IRS Economic Impact Payment (stimulus) funds deposited may be subject to special treatment under federal and state law, including executive orders.  Care must be taken to ensure compliance with all regulatory restrictions which may apply.  Credit unions are encouraged to treat such deposits in the spirit of the disaster relief legislation to enable members to use the funds, to the greatest extent possible, for basic living needs and emergencies.  Credit unions are strongly urged not to access the stimulus funds to satisfy overdrafts that existed prior to a stimulus payment being deposited, or to exercise rights of offset against the funds with respect to other debts without express agreement of the member.  If a credit union system automatically applies a stimulus payment to an account overdraft, the credit union is urged to reverse the application of the stimulus payment as promptly as possible.  Credit unions are also strongly urged not to charge against the stimulus funds for fees, such as overdraft fees, ATM fees and late payment fees.    Refer to DIFS Bulletin 2020-25-BT/CU for further information.