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#1615565 - 10/13/11 07:38 PM CIP Address for Homeless Individuals
Compliance4521 Offline
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Compliance4521
Joined: Jan 2007
Posts: 533
Washington
We have noticed that several of our customers are using the same address. When we researched the address on the internet it looks as though the address is a mail and message service place for homeless individuals. We called the number and the person that we spoke with confirmed that they are part of the a Health Center and that they do provide that service. Should we have any CIP concerns with customer's using this address?

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#1615793 - 10/14/11 01:36 PM Re: CIP Address for Homeless Individuals Compliance4521
BSARocksagain Offline
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BSARocksagain
Joined: May 2010
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Maryland
You will need to get an address from a relative or close friend as an alternative address. The Health Center can be their mailing address, but will the Health Center accept their mail?
Also this should be in your policy

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#1615954 - 10/14/11 05:08 PM Re: CIP Address for Homeless Individuals Compliance4521
Elwood P. Dowd Offline
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Elwood P. Dowd
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From the regulation:

(ii) For an individual who does not have a residential or business street address, an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual;

Assuming the center's manager is an individual; i.e. a contact person, you might reasonably use its physcial address or that of a relative. Whether their mail is delivered to either is not a factor.
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#1618851 - 10/21/11 08:39 PM Re: CIP Address for Homeless Individuals Elwood P. Dowd
Compliance4521 Offline
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Compliance4521
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Posts: 533
Washington
Thanks all for your input...those were my thoughts as well. With regards to the Manager at the Health Care is an individual I will check.

Do you beleive there would be a regulator concern if based upon learning about the 'messaging program' the healthcare has in place, that we build it into our CIP policy? We could have a few individuals using this address, and yet the process is not supported by FINCen.

I say this, because FINCen a few years back worked with various States to allow victims of domestic abuse use a state address versu the shelter address.

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#1618858 - 10/21/11 08:44 PM Re: CIP Address for Homeless Individuals Compliance4521
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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That is because domestic abuse victims are essentially in hiding. The state addresses are used to keep their location secret.
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