Returned Mail
Question: Our bank receives a lot of return mail from the post office for a variety of address problems, most of which relate to a customer moving away and not leaving a forwarding address for the post office. Are we obligated to continue sending statements (checking accounts, statement savings accounts, etc…and 1099s) to the last known address even though the customer is no longer there? We even occasionally get letters from the new occupant at the address asking us the same question. The situation seems to have many potential problems from fraud to privacy, not to mention the wasted effort and costs.
Answer: If you receive mail back from your depositor's address with the new address on it, it's tempting to simply change your address of record to the new address. But don't do it! You need to correspond with your accountholder by writing to the new address and asking them for permission to change their address. And then carefully compare signatures to your records. We were assured a short time ago by the U.S. Postal Service that any change of addresses they put through were documented and approved. Unfortunately, the practice is a little less perfect than the policy. Don't change addresses of record until instructed to do so by the depositor, and verified by your investigation.
If, on the other hand, you receive your mail back marked: "Moved - left no forwarding address", or "Addressee Deceased", then any subsequent mail should be held in your office, unopened. The piece of mail that is returned to you should also remain unopened. We used to mark the front of the envelope with the account number and the date of return and file them by account number in operations and bookkeeping. If you finally reach escheat time on the account, the old mail can then be discarded.
Copyright © 2004 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 14, No. 6, 10/10
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