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#2281998 - 03/08/23 08:38 PM Subsequent Disclosure - Undeliverable Address
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,265
We are making changes to our deposit accounts and therefore are sending updated letters/disclosures per Reg DD (1030.5(a)(1)). As expected, we have hundreds of undeliverable addresses based on previously returned mail.

In order to show a good faith effort by providing the subsequent disclosures, do we go ahead and mail them to these customers and process the return mail? Seems like a waste of time and postage but feels strange to just skip them.

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#2282002 - 03/08/23 09:20 PM Re: Subsequent Disclosure - Undeliverable Address Mel in WA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
It is a wasted effort.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2282806 - 03/29/23 08:58 PM Re: Subsequent Disclosure - Undeliverable Address Mel in WA
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,265
I'm back with a related question about returned mail. We are now receiving our subsequent disclosure letters back from USPS for various reasons, such as "temporarily away" (snowbirds), "not deliverable as addressed, unable to forward".

In order to prove subsequent disclosure compliance per Reg DD, is it acceptable to retain documentation of the original letters sent to the address on file and call it good? Could we be criticized for not notifying these account holders in a timely manner?

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#2282846 - 03/30/23 05:49 PM Re: Subsequent Disclosure - Undeliverable Address Mel in WA
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,265
Bump

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#2282848 - 03/30/23 06:21 PM Re: Subsequent Disclosure - Undeliverable Address Mel in WA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
It is not your responsibility to ensure that a customer maintains a current mailing address for notifications. Do your agreements not address that?

ADDRESS CHANGES
You are responsible for notifying us of any changes in your address. Unless we agree otherwise, changes of address may be made in writing, over the phone or through our Digital Banking channels by at least one of the account holders. Identity verification is required to make changes to an address. Informing us of your change of address on a check reorder form is not sufficient. We will attempt to communicate with you only by use of the most recent address you have provided to us. In the event mail we attempt to deliver to you is returned as a result of your failure to notify us of your change in address, we may charge a fee to your account in accordance with the Schedule of Fees applicable to your account
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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