CIP - address confirmation

Posted By: sb1

CIP - address confirmation - 11/22/10 06:45 PM

How to you verify a physical address for someone who lives in their RV and uses a mail drop box for their address, which is also the address they use on their driver's license.
Posted By: NotALawyer

Re: CIP - address confirmation - 11/24/10 07:32 PM

Does your CIP require that the physical address is verified? The regs require that the lender have and follow a CIP and form a reasonable belief who the person is.

If your CIP permits, you could use a physical address from the credit bureau report. Is the RV a "nomad" or is it kept in a park? the park address might work. Other options could be the physical address of a relative (with proof).

It will really come down to your bank's CIP.
Posted By: J2C

Re: CIP - address confirmation - 11/24/10 07:40 PM

It does come down to your bank's CIP, however the FFIEC guidance says that a person can use a next of Kin's address or another contact individual. See the footnotes on page 54 of the 2010 FFIEC manual.