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.