Interesting! Is he/she looking to increase the bank's past dues? I would have to hear a better argument then the customers could become confused, before I stopped sending them out.
I think your first two reasons should be enough (Also, don't forget the Homeownership Counseling Notice). I'm not sold on the fraud reason. If I am going to commit fraud, you would think that I would be smart enough to not set the address to a customer's real address. (I'm assuming that you are relying on the customer to catch the error.) That is just too easy to get around.
The only thing that customer would catch is that their payment wasn't posted to their account. So is this what you mean by fraud? More of a taking payments and posting them somewhere else?
I haven't seen any articles on this subject, but this is about the most I'm willing to say about this in an open forum. I think you hang your hat on the first two reasons and hold your ground. I'd only use the fraud card as a last defense. But, that's just one man's opinion.