A Positive Pay Exception Needs a Pay-or-Return Decision Before the Bank Cutoff
A positive pay exception decision checklist should match the check image to the issue file, verify payee and amount, record the cutoff, and preserve the pay-or-return decision.
A positive pay alert becomes a controlled decision when the reviewer matches the bank image to the issue file, verifies the payee and payment purpose, records the cutoff, and preserves approval or return evidence.
For a positive pay exception decision, open the bank alert and record the account, check number, presented amount, presented payee, date, exception reason, image, decision cutoff, default bank action, and authorized reviewer. Match those facts to the business's check issue file, accounting entry, invoice, approval, void or stop-payment record, signer, and vendor contact before choosing pay or return.
Do not approve because the check number looks familiar, let an email sender verify the same payment, or assume every mismatch is fraud. Encoding errors, stale issue files, duplicate presentments, altered payees, amount changes, voided checks, and legitimate replacement checks require different evidence.
The Positive Pay Check Fraud Exception Kit adds editable alert, match, verification, decision, escalation, evidence, loss, and prevention controls behind this free checklist.
Review six lanes before the cutoff
| Lane | What to capture | Decision it supports |
|---|---|---|
| Bank alert | Account, check number, image, date, amount, payee, exception reason, alert time, cutoff, default action, and portal status. | What the bank flagged and how much decision time remains. |
| Issue file | Issued number, amount, payee, issue date, batch, accounting entry, check stock, printer, signer, and upload confirmation. | Whether the presented item matches what the business says it issued. |
| Payment purpose | Vendor, invoice, purchase order, receiving proof, approval, mailing or delivery method, and replacement history. | Whether there is a valid obligation and only one supported payment. |
| Exception facts | Field mismatch, duplicate, void, stop, stale item, alteration indicators, endorsement concerns, known system error, and unexplained difference. | Whether to approve, return, hold for escalation, or report suspected fraud. |
| Decision authority | Reviewer, independent verifier, approver, decision, reason, timestamp, bank confirmation, and unresolved risk. | Who made the pay-or-return choice and what evidence supported it. |
| Escalation and closeout | Bank contact, case number, fraud report, stop or account control, vendor communication, replacement decision, loss record, and prevention fix. | What must happen after a suspicious or returned item. |
FinCEN has published an official alert on mail-theft-related check fraud and a later analysis of related filings. Those sources support taking altered and stolen checks seriously; they do not define your portal cutoff or bank liability. The bank agreement, current portal instructions, account controls, and immediate bank guidance govern the real exception decision.
Use four controls for every exception
The bookkeeper recognizes the vendor, sees a familiar amount, clicks pay, and discovers later that the payee line was altered after the check left the office.
The reviewer saves the image, matches the issue file and invoice, verifies the vendor through a known contact, records the cutoff, obtains approval, and saves bank confirmation.
Copy this exception decision row
Positive pay exception record
Bank, account ending, and portal: [details]
Alert time, decision cutoff, and default action: [details]
Check number, date, amount, and presented payee: [details]
Exception reason shown by bank: [reason]
Check image saved: [file and time]
Issue-file number, date, amount, and payee: [details]
Accounting entry and payment purpose: [details]
Invoice, purchase order, and approval: [references]
Void, stop, replacement, or duplicate history: [details]
Mismatch or alteration indicator: [fact]
Independent verification completed: [person, method, and time]
Decision: [pay / return / bank escalation]
Decision reason and authorized approver: [details]
Portal submission and confirmation: [time and proof]
Bank case number or fraud action: [details]
Vendor, accounting, and prevention follow-up: [owner and date]
Use this bank escalation script
Bank call or secure-message script:
We are reviewing positive pay exception [reference] on account ending [digits]. The presented item shows check [number], amount [amount], payee [payee], and exception reason [reason]. Our issue file shows [matching or conflicting facts]. The decision cutoff displayed is [time and time zone], and the portal default action is [action]. We have not authorized a decision because [specific concern]. Please confirm the immediate account-protection step, the correct pay-or-return handling, the case number, and any image, affidavit, stop-payment, replacement, or fraud documentation you need. We will record your instructions and submit through the authorized channel.
Get the free Emergency Triage Sheet
The first three moves for any business emergency, plus one practical fix in your inbox each week.
No spam. Unsubscribe anytime.
Worked example: three exceptions, three paths
A hypothetical distributor receives three alerts before a 1:00 p.m. bank cutoff. Check 1048 matches the issued payee and amount, but the issue file uploaded after the bank's processing window. Check 1051 was voided and replaced; the presented image is the old item. Check 1057 matches the number and amount, but the payee image differs from the approved vendor and invoice. The reviewer does not mass-approve the batch.
She documents the late-file timing for 1048 and confirms the legitimate payment. She returns and escalates the voided 1051 using the replacement record. She freezes 1057, verifies the vendor through the known number, and contacts the bank about suspected alteration before deciding. The example shows decision separation, not what a particular bank must do.
Positive pay exception checklist
- Save the alert, check image, account, exception reason, cutoff, time zone, and default bank action.
- Match check number, issue date, amount, payee, account, batch, signer, and issue-file confirmation.
- Pull the invoice, purchase order, receiving proof, accounting entry, approval, and payment purpose.
- Check void, stop-payment, stale, replacement, duplicate, and returned-item history.
- Inspect the image for changed payee, amount, endorsement, check stock, signature, or other unexplained difference.
- Verify the payment outside any suspicious email, text, or alert.
- Use independent review and the authority rules in the bank agreement.
- Record the pay, return, or escalation decision with reason and timestamp.
- Save the portal confirmation and bank case number.
- Contact the bank immediately when theft, alteration, duplicate presentment, or account compromise is suspected.
- Control any replacement payment so the business does not pay twice.
- Update issue-file timing, check custody, approval, vendor, and alert-routing controls after closeout.
FAQ: should every positive pay mismatch be returned?
No. A mismatch is a reason to investigate, not proof of fraud. The correct action depends on the check image, issue file, payment support, void or replacement history, bank agreement, portal instructions, cutoff, and bank guidance. When evidence conflicts or the exposure is material, contact the bank and qualified legal or financial advisors before guessing.
Connect check fraud to payment controls
If the request involves new electronic bank details, use the vendor ACH change verification workflow. If money already left by wire after an impersonation, move to the business email compromise wire-recall checklist. If the underlying invoice also looks wrong, use the vendor invoice discrepancy review process.
Free version vs. full kit
This article gives you the free version: the six-lane exception map, decision row, bank script, worked example, and checklist. The paid kit adds editable alert, match, decision, approval, escalation, fraud, loss, replacement, closeout, and prevention controls for a complete positive pay file.
Get the Positive Pay Check Fraud Exception Kit
The All-Access membership includes the complete kit library while membership is active. The one-time positive pay kit remains the primary next step for this article.
Fix the next one before it starts.
Join the list for the free Emergency Triage Sheet and a new practical fix every week.
No spam. Unsubscribe anytime.