Answer:
Don't pull CIP into this question, because the information you gathered to comply with CIP requirements should never be updated, regardless of future address or name changes. There is no ongoing requirement that your bank have its customer's physical address on file at all times, although you are correct in saying that a physical address is needed for proper completion of a CTR, should the need arise. It's also true that when a customer changes his or her mailing address to a P.O. box, it doesn't mean the customer has necessarily changed his or her physical address.
Unless your bank has a policy requirement that all customers provide you with a current physical address, I see no reason to close out the account of a customer who prefers not to provide one, nor can I imagine why you'd need to stop mailings.
If the occasion for a CTR presents itself, your teller should be checking to ensure that you have an acceptable address on file, and that it is current. That should involve asking the customer to confirm or supply the physical address.
First published on BankersOnline.com 1/24/11
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