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#1806019 - 04/18/13 04:20 PM Address for new accounts
sbm70001 Offline
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Joined: May 2011
Posts: 13
When opening a new acct do you require proof of address if the address on the ID is not valid?

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BSA/AML/CIP/OFAC Forum
#1806050 - 04/18/13 04:54 PM Re: Address for new accounts sbm70001
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
If when you say that "the address on the ID is not valid" you mean that it is different from the address provided by the customer, the answer is YES. How else would you verify the customer's identity and complete CIP if you do not?

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#1806053 - 04/18/13 04:59 PM Re: Address for new accounts sbm70001
Lilly C Offline
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Sunny Florida
We do too. It is part of our FACT Act procedures. We ask to see a bill or another type of identification with the address provided by the customer.

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#1806065 - 04/18/13 05:17 PM Re: Address for new accounts sbm70001
Dr.Ozya Offline
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Joined: Mar 2013
Posts: 87
Phila
Does anyone require proof of new address at address change?
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#1806069 - 04/18/13 05:21 PM Re: Address for new accounts sbm70001
sbm70001 Offline
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Posts: 13
So if you use the address on the license and they submit a change of address say 2 days from the opening date would you require proof of address then?

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#1806075 - 04/18/13 05:24 PM Re: Address for new accounts sbm70001
Lilly C Offline
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Sunny Florida
We don't. Once we verify the intial address at account opening we don't verify again when changing. I would be curious to learn if other banks do.

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#1806092 - 04/18/13 05:41 PM Re: Address for new accounts Lilly C
sbm70001 Offline
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Joined: May 2011
Posts: 13
Do you require additional proof of address at account opening or is the customers word that the address on the ID is correct sufficient?

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#1806263 - 04/18/13 09:28 PM Re: Address for new accounts sbm70001
rlcarey Online
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Galveston, TX
Many banks deem that a substantial discrepancy under their CIP and a red flag under the FCRA and require proof of new address, such as a utility bill, lease agreement, etc.
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#2078088 - 05/11/16 03:02 PM Re: Address for new accounts sbm70001
leo_bsayer Offline
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Joined: Aug 2006
Posts: 645
Sorry to resurrect this old thread, but I have a similar question regarding verifying the customer's current address. To play devil's advocate, the FFIEC Exam Manual states that, "a bank need not establish the accuracy of every element of identifying information obtained, but it must verify enough to form a reasonable belief that it knows the true identity of the customer."

When you are applying for credit online, and you are asked "out of wallet" questions, you don't have to verify your current address. Sometimes you are asked if you've lived at a previous address.

That's why I was wondering if there was an industry or examiner expectation now to verify the most current physical address of the customer, even though the exam manual indicates that every piece doesn't have to be verified.

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#2078093 - 05/11/16 03:11 PM Re: Address for new accounts sbm70001
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,796
You are here
http://www.ffiec.gov/bsa_aml_infobase/pages_manual/regulations/31CFR1020_220.pdf

nothing about the specifics of address verification

That being Said CIP regs are minimal. I certainly would not like to send a demand letter to a customer at an empty lot.
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#2078098 - 05/11/16 03:16 PM Re: Address for new accounts sbm70001
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
At my previous banks we did require secondary ID for verification of the current address if it didn't match the primary ID. At my new bank, however, our CIP policy allows for the new account opener to 'mitigate' the red flag risk by conversation with the customer. They note the customers responses as 'sticky notes' within the efund application. I would prefer the secondary ID myself, however, the bank has never had a red flag issue from this or been criticized for it on an exam or audit, so it stands. The loosening of our procedures came about (before my time) when we had a couple of employees join us from a big national bank and they informed us that bank did not require secondary ID verification. The bank then happily abandoned secondary ID verification and it was very popular. I did manage to get it reinstated for non-US citizens though, but that was the best I could do.

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#2078099 - 05/11/16 03:18 PM Re: Address for new accounts sbm70001
leo_bsayer Offline
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Joined: Aug 2006
Posts: 645
Well, a physical address is not always a mailing address. Again, I just think about those out of wallet questions that banks have for online account opening. The purpose is to verify your identity, which might not mean verifying every single piece of information.

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