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#1032800 - 09/02/08 05:57 PM Notice of address change from USPS
AuditorK Offline
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I was wondering how everyone else is going to validate address changes when the notice comes from the post office. Per the OCC webinar, banks will not be able to rely on the post office notice alone to initiate an address change. Will you be calling or e-mailing the customer, sending an address change form to the new address supplied by the post office, using a third-party service?

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#1032805 - 09/02/08 05:58 PM Re: Notice of address change from USPS AuditorK
Mrs. Rizzo Offline
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Curled up by the fire...
We are talking about sending a notice to the old address and new address just like the USPS does when you change your address.
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#1032809 - 09/02/08 06:00 PM Re: Notice of address change from USPS Mrs. Rizzo
jap Offline
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jap
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If that is the standard we are to be held to, then they should put it in writing. To have one branch of the government indicate that we cannot trust what another branch of the government tells us about a customer's address seems to be beyond ridiculous.
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#1032814 - 09/02/08 06:06 PM Re: Notice of address change from USPS jap
Skittles Online
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We are going to send an address change form to the new address. We will verify the signature against our account records.
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#1032842 - 09/02/08 06:28 PM Re: Notice of address change from USPS jap
AuditorK Offline
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jap

I totally agree with you - I'm just reiterating what I've been told.

I also know for a fact that the post office is not beyond making mistakes. My address was changed about 3 years ago with the USPS...without me initiating it. From what I can tell it was a mistake on their part, but it can happen.
Last edited by AuditorK; 09/02/08 07:51 PM.
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#1032843 - 09/02/08 06:30 PM Re: Notice of address change from USPS Skittles
AuditorK Offline
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Duchess,

This is what we've been contemplating doing. I'm struggling with what to do if the customer never sends the signed address change back to us.

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#1032856 - 09/02/08 06:34 PM Re: Notice of address change from USPS *DELETED* Skittles
AuditorK Offline
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Post deleted by AuditorK

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#1032859 - 09/02/08 06:40 PM Re: Notice of address change from USPS AuditorK
jap Offline
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jap
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I agree; I'm not trying to say that the PO doesn't make mistakes. I'm just saying that if one branch of the gov't tells us that a customer's address is now XXXXX, how could another branch of that same gov't possibly tell us that we can't rely on what the other branch just told us. Otherwise, we are being held to a higher standard than the United States government.

We are an OTS thrift and haven't heard any direction similar to what the OCC told you. Until we do (or until commentary or exam procedures indicate otherwise), we are going to rely on the PO's notice as reliable documentation of an address change.
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#1032867 - 09/02/08 06:51 PM Re: Notice of address change from USPS jap
AuditorK Offline
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Sounds like a plan as well. Thanks for weighing in on this. Some additional guidance from the regulators sure would be nice.

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#1032868 - 09/02/08 06:51 PM Re: Notice of address change from USPS jap
Skittles Online
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TN
Then I don't believe we can change the address. Maybe if the customer stops receiving their statements that will work. Right now I'm still struggling with all of this on the 'how' parts.

jap - if I go to the Post Office to change my address do they ID me? If not, anyone could change anyone else's address.
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#1032871 - 09/02/08 06:54 PM Re: Notice of address change from USPS Skittles
AuditorK Offline
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I don't believe the post office ID's a person changing an address. If things still work the same as they did a few years ago, you can pick up the "Change of Address Packet" and complete it at home and put the change form in the mail to be processed. Scary!

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#1032872 - 09/02/08 06:56 PM Re: Notice of address change from USPS AuditorK
jap Offline
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jap
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IN
Then perhaps this regulation needs to have been directed at the USPS.
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#1032880 - 09/02/08 07:05 PM Re: Notice of address change from USPS jap
RR Joker Offline
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Think about it guys. Anyone can submit and address change to the PO. You can even do it online. There is NO verification process. A yellow sticker is worthless and should never be used as validation. Sending to old and new doesn't help either because the mail will all be forwarded to the "new" address.

You will have to come up with another method. Either call the customer or wait to receive an "I'm not receiving" as Skittles mentioned.
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#1032894 - 09/02/08 07:19 PM Re: Notice of address change from USPS RR Joker
jap Offline
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jap
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I have thought about it. This yellow sticker tells me that the US government is confidently ready and willing to forward any and all of the real John Doe's mail (credit card statements, bank statements, access devices, temporary PIN notices, etc) to this new address. It is not my responsibility to audit the USPS's process for verifying an address change, nor to audit what requirements a person must go through at the BMV to get a license issued, etc.

By relying on the yellow sticker, I am adhering to the regulation by relying on an independent third party source (the government no less) for authentication of an updated address. If their controls are weak, then they need to address them. Otherwise, you are creating a never ending cycle in which you, the banker, cannot rely on any third party documentation until you have thoroughly verified the process the third party goes to prior to issuing identification or other documentation. If your third party is the hobo on the corner, then yes you probably want to do some research before determining whether you can trust that source, but if your third party is an official state or federal gov't entity, then you should be able to assume a reasonable comfort level that they are operating efficiently.
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#1032903 - 09/02/08 07:26 PM Re: Notice of address change from USPS jap
AuditorK Offline
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Just playing devil's advocate - aren't we negligent for relying on a third party (USPS), when in fact that third-party is negligent and we have knowledge of it? I guess two wrongs don't make a right. Maybe some day if the USPS beefs up their ID procedures, we can reevaluate and begin relying on them. Until then, it seems we must make up for their short fall.

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#1032937 - 09/02/08 07:47 PM Re: Notice of address change from USPS AuditorK
Mrs. Rizzo Offline
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Curled up by the fire...
What about only allowing address changes to either be done in person?
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#1032953 - 09/02/08 07:54 PM Re: Notice of address change from USPS Mrs. Rizzo
AuditorK Offline
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Allowing address changes only in person seems to be about the only solid way to ensure a valid change (assuming good CIP procedures are followed).

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#1032966 - 09/02/08 08:01 PM Re: Notice of address change from USPS Mrs. Rizzo
Marnie Offline
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Nevada
I agree with AuditorK--we do have knowledge the post office is unreliable. I also believe this is one of the reasons for the new red flag (red tape) guidelines--because the public put pressure on the government to help with identity theft and there had already been enough passing the buck. So step (1) educate all customers on how address changes will be accepted (in person or notarized request), (2)make this a talking point with customers at all new account openings, (3)if not notarized, phone the customer at the number currently on the system when receiving an address change, (4) if unable to contact, place a note on the account, (5)block mailings and wait for the customer to contact you.

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#1033219 - 09/03/08 01:15 PM Re: Notice of address change from USPS Marnie
MN Banker Offline
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According to the rules, you can "verify" a change of address request by simply sending a letter to the old address. Aren't we basically relying on the post office in this scenario too? For example:

Fraudster changes address with post office. Fraudster then comes into bank to change address. We send out a letter to the "old" address, which the post office then forwards on to the new address. The customer never receives the letter, yet we believe we've verified the address because the customer hasn't contacted us to tell us it's wrong. Or, if we've requested address service on the letter, the letter comes back to us with that little yellow sticker from the post office telling us what the "new" address is, and it agrees to our change of address request. What would you do in that scenario? Consider the address verified, or would you have some other procedure to contact the customer and verify it?

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#1033363 - 09/03/08 02:36 PM Re: Notice of address change from USPS MN Banker
Bagweaver Offline
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SW GA
Our bank was relying on the change of address stickers until a little over a year ago. We have since stopped and now have procedures in place to mail a letter along with a change of address form requiring a signature to the customer at the address given by the post office on the envelope. When we receive the form back, the signature is verified prior to mailing the returned mail to the customer.
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#1034059 - 09/03/08 09:06 PM Re: Notice of address change from USPS AuditorK
ITGuy Offline
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Alabama
We relied on the yellow stickers in the past, but stopped that practice a couple of years ago. Now, we flag the customers account so that when the customer comes into the bank and an inquiry, deposit, etc. is done on the account, an alert message is displayed. The customer service representative can then obtain the correct information from the customer.
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#1034100 - 09/03/08 10:00 PM Re: Notice of address change from USPS AuditorK
YosemiteSamIAm Offline
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Oh Lord, did they ever scream when I suggested we require address changes to be done in person!
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#1034106 - 09/03/08 10:06 PM Re: Notice of address change from USPS YosemiteSamIAm
VMack Offline
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Texas
We have not relied upon or changed a customer's address per the postal notification in several years. In fact, when we receive notification that the address is changed, the account is coded to hold mail until we receive notification from the customer. A little extreme? I guess, but it seems to have worked for us and I don't anticipate making ay changes. I'll just document the procedure in my program.
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#1034270 - 09/04/08 01:07 PM Re: Notice of address change from USPS YosemiteSamIAm
AuditorK Offline
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Originally Posted By: Coloradomountainman
Oh Lord, did they ever scream when I suggested we require address changes to be done in person!


I got the same resistance to this until I asked for an alternative way to verify the authenticity of address changes. I got no suggestions.

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#1034316 - 09/04/08 01:52 PM Re: Notice of address change from USPS AuditorK
Bagweaver Offline
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SW GA
I got the same reaction!
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