B Commingled Funds



Revised 06/14/2018



When a financial account contains both counted funds and excluded funds, it is known as “commingled funds”.  For the excluded funds to remain excluded, they must be able to be identified separately from the other funds.  However, in general they do not have to be kept in separate accounts.

Exception: Funds set aside for burial expenses must be kept separate from other non-burial-related resources and must carry a designation that the funds are to be used for burial (see MA705.D).

When withdrawals are made from an account containing commingled funds, the counted funds are considered withdrawn first, leaving as much of the excluded funds in the account as possible.  See Commingled Funds for examples.

The amount of excluded funds in the account increases when either of the following happens:

·         Funds that are excluded under the same rule are deposited; and

·         Interest earned on the excluded funds is also excluded by law.





Commingled Funds

Excluded funds maintained in the same account, policy, or investment account as non-excluded funds. 



A complete history of account transactions back to the initial deposit of excluded funds must be obtained, using the customer's own records, if possible (ex., bank statements).

The person's statement about the date and amount of a deposit of excluded funds is accepted if such statement agrees with the documents already provided showing that the customer received funds at that time.


Legal Authority


Legal Authority


42 USC 1382b

20 CFR 416.1201 (a) and (a)(1)

20 CFR 416.1208