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#1471210 - 11/22/10 06:45 PM CIP - address confirmation
sb1 Offline
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Joined: Jan 2006
Posts: 133
How to you verify a physical address for someone who lives in their RV and uses a mail drop box for their address, which is also the address they use on their driver's license.

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#1472548 - 11/24/10 07:32 PM Re: CIP - address confirmation sb1
NotALawyer Offline
Gold Star
Joined: Nov 2001
Posts: 455
Does your CIP require that the physical address is verified? The regs require that the lender have and follow a CIP and form a reasonable belief who the person is.

If your CIP permits, you could use a physical address from the credit bureau report. Is the RV a "nomad" or is it kept in a park? the park address might work. Other options could be the physical address of a relative (with proof).

It will really come down to your bank's CIP.

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#1472553 - 11/24/10 07:40 PM Re: CIP - address confirmation NotALawyer
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
It does come down to your bank's CIP, however the FFIEC guidance says that a person can use a next of Kin's address or another contact individual. See the footnotes on page 54 of the 2010 FFIEC manual.
My opinion is mine only- not my employer's!

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