Answer:
The requirement is that the bank obtain four items of information from each natural person who is a U.S. citizen: Name, SSN, residential street address, and DOB (of course, mailing address if different). There is a technical "out" on street address if the customer doesn't have one (can use APO or FPO box number address or street address of another close person). The last, I suppose, is to ensure that law enforcement can find the customer if need be.The next requirement is that the bank verify the customer's identity to its satisfaction, using appropriate means. If the bank deems it necessary to verify street address as part of its Customer ID Program, then that's what it needs to do. But the regulation doesn't specifically require that specific items of ID information (such as address, SSN, DOB) must be verified. The suggestion is that finding agreement with these data when verifying identity should provide more comfort that finding differences.How the bank verifies address (if that's what they want to do) is up to the bank. Most CIPs will allow for some variance from black and white rules to accommodate individual cases.
First published on BankersOnline.com 01/19/04
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