Reminds me of the word I hear from our outside auditor - that FinCEN now says you can't rely on publicly available information posted (by FinCEN?) at http://www.msb.gov to verify a customer has registered as an MSB.

Auditor K - did your OCC webinar point to any guidance or anything written, saying that institutions would be prohibited from relying on post office notices?

No reference to anything in writing. It was a question posed by one of the attendees to the panel of OCC staff. The answer was that you can't rely on a notice from the post office alone as a validation of address change. That's what I had jotted down in my notes from the webinar.

This is our procedure:

Change of Address Notification from the Post Office
If the Bank receives a change of address from the post office, a letter is sent to the old address and new address notifying the customer that we have received a change of address notification from the post office. The Bank’s Change of Address form is also provided with a return envelope. The letter advises the customer to notify the Bank immediately if they have not moved. The customer’s address is not changed unless the Bank receives a completed Change of Address form.

The last sentence sums it up.

Some good news! I found this on the US Postal Service page for Identity theft--so it looks like the postal service is taking proactive steps with the "move validation letter".

"In response to recommendations by the Chief Postal Inspector, a prevention measure that addresses some of consumers' concerns was adopted by the U.S. Postal Service. Aware that a crook could submit an address change to divert customers' mail without their knowledge, post offices now send a "Move Validation Letter" to both an old and new address when a change is filed. The letter requests you call an "800" number if you did not file the change."

This can be found at http://www.usps.com/websites/depart/inspect/IDtheft2.htm

I think that we'll continue what we've been doing for now.

That's great, however will the Bank have already received the tape and changed the address by the time the Postal Service receives a response back from the consumer in the event of a fraudulent address change? I think for the time being, we will continue to do what we are doing as well.

Excellent point, Mack. It's all in the timing and I agree with not relying on the USPS. But it is good to know they are at least taking some responsibility for the fraudulent address changes.

You bet Marnie. I will watch closely as the USPS may develop a process or procedure that is helpful for us yet!

Shouldn't the USPS have access to the Social Security database? If so, they can just add the field to the form and compare before they process the request.

Do you REALLY want the USPS to have access to your Social Security number, given its demonstrable record for facilitating ID theft?

I recently completed an online address change with the post office. They charged a small fee to my credit card and indicated this was a fee for the verification process.

So if we decide to Hold all mail including account statements for all mail returned with the yellow USPS label, and we continue to attempt to contact the customer with no response, does this mean that we would not be providing account statements for the purposes of Regs E & D - potentially violating the regs due to holding the statements because of the potential threat of identity theft?

John, that's why I put the smiley face in there...to indicate that a joke was in progress...

I'd also like to know if we'd be violating Reg E and D by holding statements for an indefinite time until we validate a customer's address.

Now that I ramped up the font size on my browser, I can see that the smiley face is smiling. I thought it was frowning!

That reminds me: I have an optometrist appointment this month.

I think it would be a good idea to educate customers on the procedures banks require to update a customer address. Many people think that by notifying the USPS that their address has changed, they don't need to contact their bank, etc. b/c they assume the bank will change it automatically when we receive the "yellow sticker". Maybe educating people on the national (news) level would also be nice, but highly unlikely.

For those of you who are sending out the confirmation letters for the new address, what are you doing when you can't get a response from the customer? This list keeps growing and growing for us...

The address discrepancy rules only require the bank to "verify the address with the consumer". The special rules for card issuers go on to state that "to assess the validity of the address change... one option is to notify the cardholder of the request at his or her former address..." Although this seems senseless to me if we have already received the forwarding information from the USPS, we are relying on this option for ALL change of address requests. We will begin sending pre-printed postcards with a statement that a change of address request has been received and contact information to "promptly report an incorrect address change".

12 CFR 222.91(c)(1)