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#2277128 - 10/26/22 07:35 PM Bad address after CIP is over
SteveDave Offline
100 Club
Joined: Aug 2021
Posts: 124
Hello all,

We are having some discussions at my institution about bad addresses (specifically to deposit accounts). Currently one side of the discussion wants to take bad address mail toss it in the trash and avoid talking about it. Return mail and the like. The other side of the discussion wants to track and to actively try to fix the addresses. I was asked what my opinion was. It is... lacking. In the past, my other institutions this was not a topic of discussion so I have next to no experience.

What I think I know: CIP is risk based and at the time of account opening. If I feel confident and can document a reasonable belief of the customer identification we are good and bad addresses will happen over time.

What I think I do not know: What happens when addresses go bad.

What I am asking you all: What if any rules are there that I could look into for this? What do others do when you have return mail and a bad address. Is there risk of regulator trouble if we do not attempt to fix the issue?

I appreciate your time. If you have any follow up questions I would happily answer them when I arrive to work tomorrow AM or any other day in the future.

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#2277159 - 10/27/22 12:49 PM Re: Bad address after CIP is over SteveDave
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Most banks that get returned mail at a later date just turn off statements, etc. and note their teller and other systems to ask for an updated address at the time of next contact.

If you get return mail immediately after account opening, that is a red flag that you need to deal with.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2277222 - 10/27/22 06:46 PM Re: Bad address after CIP is over SteveDave
SteveDave Offline
100 Club
Joined: Aug 2021
Posts: 124
Awesome thank you Rlcarey. I think we have documentation for new accounts having bad addresses. This gives me a good attitude going into the talks smile

Thanks

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