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Returning unemployment funds held by banks after suspicious activity

Summary ETA told state unemployment agencies how to recover federally funded benefits that banks held after detecting suspicious activity, when several states had paid into the same account. States were to request a proportional share based on each state’s contribution. The letter cautions that a bank’s hold or return of a payment alone does not establish that a claimant was overpaid or committed fraud.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
UIPL No. 19-21
Date issued
May 4, 2021
Status
Active
ETA’s listing marks this letter Active, and its PDF prints “Rescissions: None” and “Expiration Date: Continuing.”
Status last verified October 24, 2026

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This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 Unemployment Insurance
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OUI/DPM
             Washington, D.C. 20210                       DATE
                                                          May 4, 2021



ADVISORY:       UNEMPLOYMENT INSURANCE PROGRAM LETTER NO. 19-21

TO:             STATE WORKFORCE AGENCIES

FROM:           SUZAN G. LEVINE
                Principal Deputy Assistant Secretary

SUBJECT:        Benefits Held by Banks and Financial Institutions as a Result of Suspicious
                and/or Potentially Fraudulent Activity and the Proportional Distribution
                Methodology Required for Recovering/Returning Federally Funded
                Unemployment Compensation (UC) Program Funds

1. Purpose. To provide guidance to states on the proportional distribution methodology for
   recovering federally funded UC benefits, which are held by banks and financial institutions
   as a result of suspicious and/or potentially fraudulent activity.

2. Action Requested. The U.S. Department of Labor’s (Department) Employment and
   Training Administration (ETA) requests that State Administrators provide the information
   contained in this Unemployment Insurance Program Letter (UIPL) to appropriate state staff
   working with banks and financial institutions to recover improperly paid UC funds.

3. Summary and Background.

   a. Summary – With the tremendous increase in unemployment claims during the COVID-
      19 pandemic, the volume of UC deposits to banks and financial institutions initiated by
      states is in the hundreds of billions of dollars. A significant amount of this funding goes
      to direct deposit accounts. Importantly, a substantial number of fraudulent attacks have
      been perpetrated on UC programs. There are incidences of organized criminal operations
      that have used false and stolen identities to obtain UC benefits fraudulently. Banks and
      financial institutions are on alert, using their own fraud prevention data analytics to
      identify suspicious bank account activity. Banks and financial institutions have recently
      identified fraudulent claims filed in multiple states with respect to the same account,
      Social Security number, or Internet Protocol (IP) address. Upon identification of
      suspicious activity, banks and financial institutions are stopping payments and holding
      funds from such accounts. However, in many cases, some of the suspicious or potentially
      fraudulently obtained UC benefits that were held by the bank have been withdrawn, and
      there are not sufficient funds left for the bank to repay the states in full.



 RESCISSIONS                                             EXPIRATION DATE
 None                                                    Continuing

   ETA strongly encourages states to work proactively and collaboratively with banks and
   financial institutions to detect suspicious activity, ensure that accounts are not unduly
   suspended, and recover overpayments. Although there are various ways for the banks to
   distribute the funds back to the states, the Department has determined that funds should
   be returned to states in proportion to the amount each state paid into the account.

   As described below, states must request banks and financial institutions to return held
   funds paid by multiple states into the same bank account, with respect to the federally
   funded UC programs listed below, in an amount proportionate to what the state
   contributed. States are also encouraged to make this request of banks with respect to
   state-funded UC programs. Receiving what remains of returned funds in an amount that
   is proportionate to what the state contributed ensures that states are treated equally with
   respect to these challenging circumstances.

   States are also reminded that a bank or financial institution’s decision to stop payment of
   UC benefits or return UC benefit payment(s) to the state is not sufficient, by itself, to
   determine that benefits have been overpaid or that fraudulent activity occurred. See UIPL
   Nos. 01-16 and 16-21 for additional details.

   This guidance applies only to the programs discussed below in Section 4.a. of this UIPL.
   It does not apply to program funds from any other state or federally-funded government
   benefit programs, including but not limited to the Federal Emergency Management
   Agency (FEMA) Lost Wages Assistance (LWA) program, Small Business
   Administration (SBA) Economic Injury Disaster Loans (EIDL) program, or the SBA
   Paycheck Protection Program (PPP).

b. Background – Addressing improper payments and fraud is a top priority for the
   Department and the entire unemployment insurance (UI) system. States play a
   fundamental role in ensuring the integrity of this system. Overpayment recovery is
   critical to protect both state and federal UI trust funds and must be given the same
   priority as overpayment prevention and detection. A number of guidance documents
   address this priority. For example, UIPL No. 05-13 advises states on overpayment
   recovery through offset as required by the Middle Class Tax Relief and Job Creation Act
   of 2012 (Public Law (Pub. L.) 112-96, February 22, 2012). UIPL No. 23-20 advises
   states that certain overpayment recovery activities required for the regular UI program are
   also required for particular Coronavirus Aid, Relief, and Economic Security (CARES)
   Act of 2020, (Pub. L. 116-136, March 27, 2020) programs (benefit offsets, Treasury
   Offset Program, cross program offsets, and interstate reciprocal recoveries), and
   recommends that additional overpayment activities be implemented where allowed by
   law. UIPL No. 28-20 reminds states of available integrity resources and describes
   funding available to states to prevent and detect fraud and identity theft and recover fraud
   overpayments in the CARES Act Pandemic Unemployment Assistance (PUA) and
   Pandemic Emergency Unemployment Compensation (PEUC) programs. UIPL No. 28-
   20, Change 1, informs states about the availability of additional funding to states to
   support identity verification or validation of PUA claimants and to assist states with

        efforts to prevent and detect fraud and to recover fraud overpayments in the PUA and
        PEUC programs.

4. Guidance.

    a. Federally funded UC programs.

        The programs at issue require the Secretary to fully reimburse the states for benefit
        payments either in advance or by way of reimbursement, as determined by the Secretary,
        in such amounts as the Secretary estimates the states will be entitled to receive. Because
        the Secretary has the same repayment obligation with respect to every state, the
        Department has determined that states must follow a uniform recovery methodology
        when funds are held due to suspicious or potentially fraudulent activity, but the bank is
        unable to return all of the funds paid by multiple states into the same bank account
        because some funds have already been withdrawn. Accordingly, states are required to
        ask banks/financial institutions to use the proportional distribution methodology
        described in Section 4.c. for returning benefit funds with respect to the following
        federally funded UC programs.

            i.   Permanent federal programs:

                     Unemployment Compensation for Federal Employees (UCFE) (5 U.S.C.
                      Chapter 85, subchapter I). See 5 U.S.C. 8505.

                     Unemployment Compensation for Ex-Servicemembers (UCX) (5 U.S.C.
                      Chapter 85, subchapter II). See 5 U.S.C. 8521(b), which applies the UCFE
                      provisions to the UCX program, subject to modifications not relevant here.

           ii.   Temporary programs created by the CARES Act1:

                     PUA (Section 2102; 15 U.S.C. 9021). See 15 U.S.C. 9021(f); UIPL Nos. 16-
                      20 and 16-20, Changes 1-5.

                     PEUC (Section 2107; 15 U.S.C. 9025). See 15 U.S.C. 9025(c); UIPL Nos.
                      17-20 and 17-20, Changes 1-3.



1
  The CARES Act was amended on December 27, 2020, by the Consolidated Appropriations Act, 2021 (Pub. L.
116-260, Division N, Title II, Subtitle A (referred to as the “Continued Assistance Act”), December 27, 2020), and
by the American Rescue Plan Act of 2021 (ARPA) (Pub. L. 117-2, March 11, 2021). The CARES Act provides
states with administrative funding to operate the program through an agreement with the Department. This
agreement, entitled “Agreement Implementing the Relief for Workers Affected by Coronavirus Act” (Agreement),
was signed by each state in March 2020, remains in effect, and incorporates by reference the modifications and
extensions required by the Continued Assistance Act and ARPA. Benefits under the listed program are payable to
weeks of unemployment ending on or before September 6, 2021. See UIPL Nos. 14-20, 09-21, and 14-21.

                      Federal Pandemic Unemployment Compensation (FPUC) (Section 2104; 15
                       U.S.C. 9023). See 15 U.S.C. 9023(d); UIPL Nos. 15-20 and 15-20, Changes
                       1-4.

                      Mixed Earners Unemployment Compensation (MEUC) (Section 2104; 15
                       U.S.C. 9023).2 See 15 U.S.C. 9023(d) and UIPL Nos. 15-20, Changes 3-4.

           iii.    Programs temporarily funded by federal benefits under the CARES Act:

                      First Waiting Week (CARES Act Section 2105; 15 U.S.C. 9024). See 15
                       U.S.C. 9024(c) and UIPL No. 20-20. The CARES Act provides temporary
                       100 percent federal funding for the first week of compensable regular
                       unemployment for states with no waiting week. This guidance applies to only
                       first waiting week benefits that are fully federally funded.

                      Short-Time Compensation (STC) (26 U.S.C 3306(v); CARES Act Section
                       2108; 15 U.S.C. 9026). See 15 U.S.C. 9026(a) and UIPL No. 21-20. STC
                       programs are funded by states. However, Section 2108 of the CARES Act (15
                       U.S.C 9026) authorizes temporary full federal financing of STC payments in
                       states with an existing STC program in state law through weeks of
                       unemployment ending on or before September 6, 2021. This guidance applies
                       to only STC benefits that are fully federally funded.

            iv.    Program temporarily funded by federal benefits under the Families First
                   Coronavirus Response Act, Division D (Emergency Unemployment
                   Insurance Stabilization and Access Act (EUISAA) of 2020), (Pub. L. 116-127,
                   March 18, 2020):

                      Extended Benefits (EB) (Federal-State Extended Unemployment
                       Compensation Act of 1970) (EUCA) (26 U.S.C. 3304, note). See EUCA
                       Section 204; UIPL Nos. 13-20 and 13-20, Change 1; UIPL Nos. 24-20 and 24-
                       20, Changes 1-2. EB is 50 percent federally funded and 50 percent state-
                       funded. However, EUISAA Section 4105(a) authorized temporary 100
                       percent federal funding of sharable EB costs for weeks of unemployment
                       beginning after March 18, 2020, and before December 31, 2020. This was
                       extended by ARPA Section 9022 to weeks of unemployment beginning before
                       September 6, 2021. The proportional distribution requirement applies only to
                       EB payments that are 100 percent federally funded.

      b. Banks and Financial Institutions Returning UC Funds. States are encouraged to work
         closely with their Originating Depository Financial Institution (ODFI) with respect to the
         return of UC funds. The ODFI is the state UI agency’s partner bank. State UI agencies
         initiate the payment of unemployment benefits when they send a payment transaction file


2
    The MEUC program was created by the Continued Assistance Act.

         to their ODFI. The ODFI sends payment entries into the ACH Network3 on behalf of the
         state UI agency. Only banks can initiate ACH transactions. The ODFI sends ACH
         transactions to a Receiving Depository Financial Institution (RDFI). The RDFI is the
         bank of the claimant receiving the UC benefit payment(s). The RDFI is responsible for
         posting the ACH transaction to the claimant’s bank account. In a situation where the
         recipient of the UC benefit payment(s) has a bank account at the state UI agency’s
         partner bank, the ODFI and RDFI are the same.

         Banks and financial institutions have fraud prevention data analytics to identify
         suspicious account activity, and both ODFIs and RDFIs have been stopping payments
         and holding UC funds they have identified as potentially fraudulent. It is critical that
         state UI programs are in regular communication with their ODFI and the RDFIs that are
         attempting to return funds to ensure an efficient and expeditious recovery/return of any
         UC funds when appropriate. The proportional distribution method applies to recovery of
         funds from both ODFIs and RDFIs.

         The Department reminds states that a bank or financial institution’s decision to suspend,
         restrict, stop, or return UC benefit payments is not sufficient, by itself, to stop UC benefit
         payments, make a determination of fraud, or establish an overpayment. The state must
         follow the adjudication standards outlined in Sections 303(a)(1) and 303(a)(3) of the
         Social Security Act (SSA) (42 U.S.C. 503(a)(1) and (3)) and the Standard for Claim
         Determination (CD) (20 C.F.R. Part 614, Appendix B). See UIPL Nos. 01-16 and 16-21
         for additional details.

    c. Required instructions to banks for returning funds. States must request banks and
       financial institutions to return funds paid with respect to any of the above-listed federal
       UC programs into a single account by multiple states in an amount proportional to what
       the state contributed if the bank is holding an amount that is insufficient to allow full
       reimbursements to all states.

             For example, consider a situation where a bank holds $20,000 in total deposits from
             three different states (States A, B, and C) in a single account. State A had deposited
             $10,000, and States B and C had each deposited $5,000. Fraudsters withdraw
             $10,000 from the account. States A, B, and C would request the bank to distribute the
             $10,000 of benefits remaining in the bank account proportionally to what each state
             paid. This means that 50 percent, or $5,000 of the remaining $10,000, would be
             returned to State A, and 25 percent of the remaining $10,000, or $2,500, would be
             returned to both State B and State C.




3
  The ACH Network is the national automated clearing house for electronic funds transfers. It processes electronic
financial transactions, such as direct deposit and direct payments, for consumers, businesses, and federal, state, and
local governments.

             State               Total Benefits Paid      Percent of     Amount Returned
                                 into Account             Total          by Bank
             State A             $10,000                  50%            $5,000
             State B             $5,000                   25%            $2,500
             State C             $5,000                   25%            $2,500
             Total               $20,000                  100%           $10,000

   d. Regular UC Programs. The Department defers to state law regarding the method of
      distribution for any regular, state-funded UC programs (including payments made under
      the Self-Employed Assistance (SEA) program). States should work with banks and
      financial institutions to differentiate between payments from the regular UC programs
      and payments from federally funded UC programs. However, to simplify the
      recovery/return process, the Department strongly encourages states to apply the same
      proportionate distribution methodology to the recovery of regular UC funds. The
      Department also encourages states to work in partnership with each other and with banks
      and financial institutions to facilitate the expeditious recovery/return of UC funds
      identified by the financial institutions as potentially fraudulent.

5. Inquiries. States should direct inquiries to [email protected] and copy the appropriate ETA
   Regional Office.

6. References.

      American Rescue Plan Act of 2021 (ARPA), Pub. L. 117-2, Title IX, Subtitle A, Crisis
       Support for Unemployed Workers (March 11, 2021);
      Consolidated Appropriations Act, 2021, Pub. L. 116-260, Division N, Title II, Subtitle
       A, the Continued Assistance for Unemployed Workers Act of 2020 (December 27, 2020);
      Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub. L. 116-136, Title II,
       Subtitle A, Relief for Workers Affected by Coronavirus Act;
      Families First Coronavirus Response Act, Pub. L. 116-127, Division D Emergency
       Unemployment Insurance Stabilization and Access Act of 2020 (EUISAA) (March 18,
       2020);
      Section 204 of the Federal-State Extended Unemployment Compensation Act of 1970
      (EUCA) (26 U.S.C. §3304 note);
      Section 303 of the Social Security Act (SSA) (42 U.S.C. §503);
      Claim Determination (CD) Standards set forth at 20 C.F.R. 614 Appendix B;
      Administrative Procedure Act, 5 U.S.C. §553;
      5 U.S.C §8505;
      5 U.S.C §8521;
      19 U.S.C. §2291;
      42 U.S.C. §5177(a);
      UIPL No. 16-21, Identity Verification for Unemployment Insurance (UI) Claims, issued
       April 13, 2021, https://wdr.doleta.gov/directives/corr_doc.cfm?docn=9141;

   UIPL No. 14-21, American Rescue Plan Act of 2021 (ARPA) - Key Unemployment
    Insurance (UI) Provisions, issued March 15, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?docn=5669;
   UIPL No. 09-21, Continued Assistance for Unemployed Workers Act of 2020 (Continued
    Assistance Act) - Summary of Key Unemployment Insurance (UI) Provisions, issued
    December 30, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3831;
   UIPL No. 28-20, Change 1, Additional Funding for Identity Verification or Verification
    of Pandemic Unemployment Assistance (PUA) Claimants and Funding to Assist with
    Efforts to Prevent and Detect Fraud and Identity Theft as well as Recover Fraud
    Overpayments in the PUA and Pandemic Emergency Unemployment Compensation
    (PEUC) Programs, issued January 15, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9897;
   UIPL No. 28-20, Addressing Fraud in the Unemployment Insurance (UI) System and
    Providing States with Funding to Assist with Efforts to Prevent and Detect Fraud and
    Identity Theft and Recover Fraud Overpayments in the Pandemic Unemployment
    Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC)
    Programs, issued August 31, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8044;
   UIPL No. 24-20, Change 2, American Rescue Plan Act of 2021 (ARPA) - Provisions
    Affecting the Federal-State Extended Benefits (EB) Program, issued April 07, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7443;
   UIPL No. 24-20, Change 1, Continued Assistance for Unemployed Workers Act
    (Continued Assistance Act) of 2020 - Provisions Affecting the Federal-State Extended
    Benefits Program, issued December 31, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7779;
   UIPL No. 24-20, Temporary Changes to the Federal-State Extended Benefits (EB)
    Program in Response to the Economic Impacts of the Coronavirus Disease 2019
    (COVID-19) Pandemic Emergency, issued May 14, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7132;
   UIPL No. 23-20, Program Integrity for the Unemployment Insurance (UI) Program and
    the UI Programs Authorized by the Coronavirus Aid, Relief, and Economic Security
    (CARES) Act of 2020 - Federal Pandemic Unemployment Compensation (FPUC),
    Pandemic Unemployment Assistance (PUA), and Pandemic Emergency Unemployment
    Compensation (PEUC) Programs, issued May 11, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4621;
   UIPL No. 21-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 -
    Short-Time Compensation (STC) Program Provisions and Guidance Regarding 100
    Percent Federal Reimbursement of Certain State STC Payments, issued May 3, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9622;
   UIPL No. 20-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 -
    Operating, Financial, and Reporting Instructions for Section 2105: Temporary Full
    Federal Funding of the First Week of Compensable Regular Unemployment for States
    with No Waiting Week, issued April 30, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6324;

   UIPL 17-20, Change 3, American Rescue Plan Act of 2021 (ARPA) - Pandemic
    Emergency Unemployment Compensation (PEUC) Program: Extension, Elimination of
    Transition Rule, Increase in Total Benefits, and Extension of Coordination Rule, issued
    March 26, 2021, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9169;
   UIPL 17-20, Change 2, Continued Assistance for Unemployed Workers Act of 2020-
    Pandemic Emergency Unemployment Compensation (PEUC) Program: Extension,
    Transition Rule, Increase in Total Benefits, and Coordination Rules, issued December
    31, 2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9291;
   UIPL 17-20, Change 1, Coronavirus Aid, Relief, and Economic Security (CARES) Act of
    2020-Pandemic Emergency Unemployment Compensation (PEUC) Program: Questions
    and Answers, and Revised Reporting Instructions for the PEUC ETA 227, issued May 13,
    2020, https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8689;
   UIPL 17-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020-
    Pandemic Emergency Unemployment Compensation (PEUC) Program Operating,
    Financial, and Reporting Instructions, issued April 10, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8452;
   UIPL 16-20, Change 5, Expanded Eligibility Provisions for the Pandemic Unemployment
    Assistance (PUA) Program, issued February 25, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3202;
   UIPL No. 16-20, Change 4, Continued Assistance to Unemployed Workers Act of 2020 –
    Pandemic Unemployment Assistance (PUA) Program: Updated Operating Instructions
    and Reporting Changes, issued January 08, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6973;
   UIPL No. 16-20, Change 3, Coronavirus Aid, Relief, and Economic Security (CARES)
    Act of 2020 – Eligibility of Individuals who are Caregivers for Pandemic Unemployment
    Assistance (PUA) in the Context of School Systems Reopening, issued August 27, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3849;
   UIPL No. 16-20, Change 2, Coronavirus Aid, Relief, and Economic Security (CARES)
    Act of 2020 – Pandemic Unemployment Assistance (PUA) Additional Questions and
    Answers, issued July 21, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5479;
   UIPL No. 16-20, Change 1, Coronavirus Aid, Relief, and Economic Security (CARES)
    Act of 2020 – Pandemic Unemployment Assistance (PUA) Program Reporting
    Instructions and Questions and Answers, issued April 27, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5899;
   UIPL No. 16-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 –
    Pandemic Unemployment Assistance (PUA) Program Operating, Financial, and
    Reporting Instructions, issued April 05, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=4628;
   UIPL No. 15-20, Change 4, American Rescue Plan Act of 2021 (ARPA) - Extensions to
    the Federal Pandemic Unemployment Compensation (FPUC) Program and Mixed
    Earners Unemployment Compensation (MEUC) Program, issued March 26, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3728;
   UIPL No. 15-20, Change 3, Continued Assistance for Unemployed Workers (Continued
    Assistance) Act of 2020 — Federal Pandemic Unemployment Compensation (FPUC)
    Program Reauthorization and Modification and Mixed Earners Unemployment

    Compensation (MEUC) Program Operating, Reporting, and Financial Instructions,
    issued on January 05, 2021,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6122;
   UIPL No. 15-20, Change 2, Coronavirus Aid, Relief, and Economic Security (CARES)
    Act of 2020—New Data Collection Instrument and Revised Reporting Instructions for
    Federal Pandemic Unemployment Compensation (FPUC), issued on June 15, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7785;
   UIPL No. 15-20, Change 1, Coronavirus Aid, Relief, and Economic Security (CARES)
    Act of 2020 – Federal Pandemic Unemployment Compensation (FPUC) Program
    Reporting Instructions and Questions and Answers, issued on May 09, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3946;
   UIPL No. 15-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 –
    Federal Pandemic Unemployment Compensation (FPUC) Program Operating,
    Financial, and Reporting Instructions, issued on April 04, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=9297;
   UIPL No. 14-20, Change 1, Coronavirus Aid, Relief, and Economic Security (CARES)
    Act of 2020 – Questions and Answers, issued August 12, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3791;
   UIPL No. 14-20, Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 -
    Summary of Key Unemployment Insurance (UI) Provisions and Guidance Regarding
    Temporary Emergency State Staffing Flexibility, issued April 02, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3390;
   UIPL No. 13-20, Change 1, Families First Coronavirus Response Act, Division D
    Emergency Unemployment Insurance Stabilization and Access Act of 2020 (EUISAA) -
    Reporting Instructions, Modification to Emergency Administrative Grants Application
    Requirement, and Questions and Answers, issued May 04, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=5374;
   UIPL No. 13-20, Families First Coronavirus Response Act, Division D Emergency
    Unemployment Insurance Stabilization and Access Act of 2020, issued March 22, 2020,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8634; and
   UIPL No. 05-13, Work Search and Overpayment Offset Provisions Added to Permanent
    Federal Unemployment Compensation Law by Title II, Subtitle A of the Middle Class Tax
    Relief and Job Creation Act of 2012, issued January 10, 2013,
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3698.

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