Hello,

Some folks and I were having an internal discussion about how a bank documents a physical address for someone who is homeless or who is residing in a domestic violence shelter (two separate instances). How do you handle those situations?

We accept a domestic violence shelter as a physical address and have been through multiple examinations with no issues.

The regulaton notes that for a homeless person you can use the physcial address of a next of kin to satisfy the requirement.

1020.220 Customer identification program requirements for banks.

(3) Address, which shall be:

(i) For an individual, a residential or business street address;
(ii) For an individual who does not have a residential or business street address, an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual; or
(iii) For a person other than an individual (such as a corporation, partnership, or trust), a principal place of business, local office, or other physical location

Thank you, all!