This is not a regulatory issue, it is a "Why place the liability risk on the Bank issue?"
Generally with these arrangements the statements need to be kept under dual control. The customer has to provide identification and sign acknowledging receipt of the statements.
A. Why take up the space in your branch for those customers who never pick up the statements.
B. Is it worth the risk on a safety and soundness audit to be written up because someone forgot to get a signature?
C. What do we do when someone accidently gives a customer the wrong statement?
D. Are you being compensated in the form of a monthly service fee for all of the hassle of managing this?
E. If the customer really doesn't want statements mailed home for whatever reason, suggest e-Statements for free or suggest they invest in a post office box.
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