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When switching from a bank to a credit union for an HSA.


The old bank had the following text on the DEPOSIT SLIP, which was provided in the envelope together with their VISA debit card:

Prior year contributions must be postmarked between January 1 and the applicable Federal tax return deadline (typically April 15).*

*This does not include extensions.


The new credit union required HSA account opening documents to be notarised by a local notary public, even though I've already have had several deposit accounts with them, and they do have an online banking web-site, supposedly capable of opening new account (but not "tax-advantaged accounts", according to them).

I notarised the application to open the new account on April 15, and mailed them back their BUSINESS REPLY MAIL packet the same day, prior to the last collection time at USPS, to make sure it was postmarked April 15, too.

However, they refused to make a prior year contribution, claiming my paperwork did not arrive until April 20.

Are they allowed to ignore the postmark date?

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The "must be postmarked" language might be just from the old bank itself, not from the IRS. The language I see in Publication 969 only says "You can make contributions to your HSA for 2014 until April 15, 2015."

In this case, it is understandable that the credit union you have the new account with does not want to accept the contribution for tax year 2014. You didn't have an account with them in 2014. You didn't even send out the paperwork to them to open the account until last week, and they didn't open your account until this week, after the deadline.

It is unfortunate, but I don't think you'll be able to force them to do anything differently here. It is just too late.

I do know how that feels. I had a somewhat similar circumstance with my HSA, the first year I had the account. I contributed money to the HSA using my credit union's website, transferring money from my checking account into my HSA, as I was told to do. In January and February of the following year, I made more contributions this way, thinking that I was making them for the previous tax year. However, they never got coded correctly by the credit union, and I later found out that the credit union counted those as contributions for the current year. As a result, I was essentially denied the full contribution limit for that year, and had a bit of a paperwork nightmare. Now, if I have to make a prior year contribution, I only make it in person, and they have a form they have me fill out each time I do.

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  • Why would you make a contribution in January and February, thinking that it must be applied for the prior year, without explicitly specifying so? That just makes no sense; how could anyone possibly know what you have had in mind? On the other hand, all tax documents are due on April 15, and, traditionally, USPS acts as the official acceptance and timestamping place for such documents; to require actual receipt by April 15 would be to deny the applicant of their right to take their time as they please.
    – cnst
    Apr 24 '15 at 19:53
  • @cnst I've learned a lot by making mistakes. :) My thinking at the time was that I didn't need to tell the CU which year it was for, because I would tell the IRS that on my tax return. Obviously, I found out that I was wrong. Apr 24 '15 at 20:03
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The slips from your bank for your HSA account are for an account already established and thus the bank is willing to accept your deposits even if they arrive at the bank after the April 15 deadline, as long as the postmark is April 15 or earlier. The account exists in the bank, they know who you are, and that the payment is received after April 15 is just due to the normal (or even abnormal) delays in postal delivery.

For the new account that you tried to establish (with appropriate notarization and timely postmark etc), the credit union could not have received the paperwork as of the close of business on April 15 (except in the very unlikely circumstance that a local letter deposited in the mailbox in the morning gets delivered the same day by USPS: don't extrapolate from stories of how mail was delivered in London in Victorian times). Ergo, you did not have an HSA account in the credit union as of April 15, and they are perfectly correct in refusing to open an account with a April 15 date and put money into it for the previous tax year.

To answer the question asked:

Are they allowed to ignore the postmark date?

Yes, not only are they allowed to ignore the postmark date, the IRS insists that they ignore the postmark date. The credit union prefers to report only the truth: as of April 15, you had not established an HSA account as of April 15; to say otherwise would be making a false statement to the IRS.

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  • You seem to contradict your own self in your answer. First, you say the old bank is correct for allowing extra time for postal delays. Then, you say the new bank is correct for not allowing any time for postal delays at all, and that, in fact, IRS requires them doing so. Is your answer meant to be a joke, a ridicule of how banks make up their own interpretation of the rules, for whatever agenda they're trying to fill? (And, for what it's worth, I've been a customer with the "new" credit union bank for more than 12 years, so, it's not like they don't know me or anything.)
    – cnst
    Apr 24 '15 at 19:47
  • The credit union might know you ever since your parents established a UGMA account in your name the day you were born, not just the 12 years you claim, but the credit union does not have in its possession on April 15 the paperwork that establishes your HSA account. The IRS allows your previous bank to accept things till April 15 because you already have an account with them; sheesh! you have even received a deposit slip and a Visa debit card from them, Your account is on their books. With the credit union, you don't have an HSA account as of 4/15. Apr 25 '15 at 2:49
  • That seems like a rather arbitrary distinction, to ignore the postmark date only for account opening, but not for deposits. Doesn't it follow that it's their fault for not having had opened the account on April 15, since I DID make a deposit on April 15?!
    – cnst
    Apr 25 '15 at 4:09
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    @cnst Arguing with us here won't do you any good. We are just trying to explain the credit union's actions. If you don't agree, argue with the credit union. However, I don't think it will do you any good in this case. Apr 25 '15 at 14:46
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I had a situation like this also. A client deposited an IRA check to his local P.O. prior to collection p/up, thinking this meant it would be postmarked April 15. It may have been picked up, but wasn't postmarked until the next day, and my firm refused to consider it as timely. I do remember discussing it w/my Retirement Services Dept. Maybe they made an exception for me and my client, but maybe not. I don't remember. Good luck.

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  • thanks! my credit union didn't tell me when it was postmarked, only when they've actually received it; i dropped it at a GMF (USPS General Mail Facility in Austin), so, they're supposed to postmark it appropriately
    – cnst
    Apr 24 '15 at 15:41

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