Learn More - Click Here!

New Reply Thread Options
#1973432 - 10/31/14 04:44 PM Address Maintenance
Anonymous
Unregistered

If you have an existing relationship with a borrower or depositor and their address becomes invalid, what action is required?

I have a CD secured loan that has reached maturity. The instrument is open-ended and still has an outstanding balance. Payments are still being made to the loan but the phone number and address on file are no longer valid. We receive return mail and the number is disconnected. Is this a red flags issue, a CIP issue, a combined issue? What steps should be taken to ensure compliance?

Return to Top Reply Quote Quick Reply Quick Quote
#1973661 - 11/03/14 04:07 PM Re: Address Maintenance Anonymous
trout22 Offline
Gold Star
Joined: Nov 2004
Posts: 313
Check with your state, but if you are unable to establish communication it may be considered a dormant account and you'd need to look at the timeframe to escheat.

Return to Top Reply Quote Quick Reply Quick Quote
#1973854 - 11/03/14 10:31 PM Re: Address Maintenance Anonymous
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
I don't think escheat would be a concern here...
1) There are credits to the loan which means the account is "active."
2) The CD is loan collateral, so my understanding is that is not escheatable until the loan is paid off.

I assume the loan gives you the right to pull credit reports... is there nothing on there with a new address?

Return to Top Reply Quote Quick Reply Quick Quote
#1973864 - 11/03/14 10:54 PM Re: Address Maintenance Anonymous
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,388
With respect to the bad address, this is not a compliance issue. It is an operational issue.

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale