Address Changes on New Accounts

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Question:

We continue to have issues collecting customers current physical addresses when opening new accounts. Our frontline thinks they find loopholes in our policy, deviating from the intent of the policy, and they create larger problems. Is it permissible to have a policy or procedure in place for changing the address on a new account for a new customer within 30 days of the date opened? Say if a customer opens an account on the 10th and then comes in on 21st to change their address, do other banks have a policy to collect a proof of address at this time since it is a new account?

Answer:

This should be addressed in your board approved CIP as well as your FACT Act Identity Theft procedures. If staff does not follow these procedures, there should be accountability standards in place.

It sounds like your institution has a compliance culture issue, rather than a policy/procedure issue.