Thread Starter: Anon Deux
Title: Re: Address validation
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I agree with what BrianC said, for the most part, but want to emphasize that of course, any contemplated changes to this sort of procedure should be coming from the Board of Directors or the person appointed as CIP Officer (generally, your BSA Officer). This would not be something for management or marketing or whoever to just decide to change, then notify BSA afterwards. This is in the CIP/BSA domain and any changes of this nature should be requested well in advance, as it may require some changes to the Board's Risk Assessment, changes to how new accounts or monitored or how addresses are verified or re-verified after opening, and so on. This is not something to change lightly, if at all. Besides the compliance considerations, you'd also be inviting more fraud into the bank, by stating that you could verify an address using a piece of paper literally any idiot could make at home.
If your CIP/BSA Officer feels this poses unacceptable risk given your location, geographic areas you serve, customer base, etc., then I'd counsel respecting that opinion. It's their job to let you know if you're weakening your CIP procedures to an unacceptably risky extent.
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