We are preparing to send the letters. The current number and address on file, the customer cannot be reached. Can chexsystems be used to obtain the latest address?

What permissible purpose do you have?

Sec. 604(a)(3) To a person which it has reason to believe

(A) intends to use the information in connection with a credit transaction involving the consumer on whom the information is to be furnished and involving the extension of credit to, or review or collection of an account of, the consumer; or

(B) intends to use the information for employment purposes; or

(C) intends to use the information in connection with the underwriting of insurance involving the consumer; or

(D) intends to use the information in connection with a determination of the consumer's eligibility for a license or other benefit granted by a governmental instrumentality required by law to consider an applicant's financial responsibility or status; or

(E) intends to use the information, as a potential investor or servicer, or current insurer, in connection with a valuation of, or an assessment of the credit or prepayment risks associated with, an existing credit obligation; or

(F) otherwise has a legitimate business need for the information

(i) in connection with a business transaction that is initiated by the consumer; or

(ii) to review an account to determine whether the consumer continues to meet the terms of the account.

The short answer to Randy's question is, "None." From an ID Theft perspective, I would not be sending any letters with sensitive information to an address that my customer has not provided me. Suppose that the information you obtain from a third party service was placed there by someone who has stolen your customer's identity.

The safest course for you bank if you do not have valid contact information for a customer is to remit the funds in accordance with the state's escheatment laws.