QUESTION: We allow our customers to complete a change of address form in the secure area of our online banking site. Do we also need to have a signed change of address form in addition to the customer making the request to change their address from the secure (password required) section of our online banking site?
ANSWER: The issue is whether your bank has taken adequate caution in ensuring that the request has come from the customer (I.e. the customer is in fact who they say they are when they sign into your online banking system). Access to your system, via username and password, authenticates the customer and gives them access to their account information. While in that area, if a customer makes a request to change their address the presumption is that the request has come from the authenticated user. However, if the username and password had been stolen by an unauthorized fraudulent party and a request was made to change the customers address, preventing the customer to reviewing their financial statement, there could potentially be a liability problem.
Our recommendation is that you perform additional diligence by contacting the customer via phone to verify the change of address. We do not believe that you must have a signed form requesting the change of address, in additional to the electronic request. The follow-up verification via phone should be adequate.
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