BANKERSONLINE.COM -- Executive Banker Briefing -- Changes in Customer's Address -- Lucy Griffin

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Changes in Customer's Address
Lucy Griffin, BOL Guru
Editor, Compliance Action

In many ways, it's simply common sense, but the rule regarding treatment of changes in customer addresses is now in final form. The rule contains two primary elements. First, a bank must maintain procedures to verify customer addresses. Second, the bank must have procedures for reporting that address to the credit bureau and for confirming addresses when the credit bureau's address for the consumer differs.

Banks should take steps to protect both their customer and the safety and soundness of the bank by establishing the correct identity and address of their customers. Since identity theft is so often accompanied with a change of address submitted by the thief, the rule requires special procedures to verify the address. The bank's program can be based on its Customer Identification Program (CIP) as long as that program includes a careful review of documents submitted by the customer.

The bank should also have a procedure for verifying a change of address. The rule suggests several methods including mailing to the old address to confirm the address change.

To comply with the second arm of the rule, the bank must have policies and procedures for responding to notification from the credit bureau that there is an address discrepancy. This procedure includes furnishing the credit bureau with an address that the consumer has reasonably confirmed to be correct.

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First published on BankersOnline.com 1/8/2008

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Need FCRA/FACTA Training?
Check out our selection of videos and CD ROMs.
Whether you're looking for quick training for all your lenders or your entire staff in a short amount of time (approximately 20 minutes) and want to use a video, complete with a trainer's guide and attendee handouts, or you're looking for more in-depth training for specialists (two hour webinars and/or CD ROMs), we've got you covered!

VIDEOS
FACTA: Responding to Identity Theft, written and presented by Lucy Griffin. (Runs approximately 20 mins.)

FACTA: Complying with the Medical Informational Rule, written and presented by Lucy Griffin.

CD ROMs
Conducting the Required Identity Theft Risk Assessment. Presented by Mary Beth Guard and Jack Holzknecht.

Implementing the Red Flag Guidelines. Presented by Mary Beth Guard and Jack Holzknecht.

Accurate Credit Reporting and Handling Direct Disputes: New Proposed Rules. Presented by Mary Beth Guard and Jack Holzknecht.