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#1072146 - 10/28/08 07:00 PM Address Change Procedures ... comments?
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Could I have everyone's opinion if this is sufficient policy/procedure for Address Changes?

Address Changes

1. Made In Person:
a. The Bank will have reasonable belief of the identity of the customer by obtaining identification in accordance with the Bank’s BSA/AML/CIP/OFAC Policy at the time of the address change.

2. Made via phone/fax/email
a. The Bank will have reasonable belief of the identity of the customer by verifying information contained in it’s records; such as:
i. Password
ii. Other information not readily available on a credit report. (Last Deposit, etc …)
b. The Bank will have reasonable belief of the validity of the address by sending a notice of change of address to both the old address and the new address provided.

3. Made via secure internet connection.
a. The Bank will have reasonable belief of the identity of the customer if the email is submitted after the customer has completed Multi-Factor Authentication.
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My opinions are my own, and not that of my employer.

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#1073706 - 10/30/08 05:18 PM Re: Address Change Procedures ... comments? WonderWoman
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
You should also discuss your procedure regarding notification from the post office. This is from my Red Flag Program:

Request Made in Person
If the customer is physically present, a Bank employee will provide a Change of Address form for the customer to complete and sign. The completed form is sent to the Central Operations Department for processing. A Central Operations Department employee will verify the customer’s signature before changing the address on the Jack Henry system.

Request Made by Mail
If a request is made by mail, a Central Operations Department employee will verify the customer’s signature before changing the address on the Jack Henry system. In some cases, the Bank may choose to contact the customer before making the address change to ensure that the request is legitimate.

Request Made by Phone
The Bank will accept a change of address request by phone if the customer’s identity can be verified. Such requests will be followed-up with a letter to the customer confirming the old and new address.

Change of Address Notification from the Post Office
If the Bank receives a change of address from the post office, a letter is sent to the old address and new address notifying the customer that we have received a change of address notification from the post office. The Bank’s Change of Address form is also provided with a return envelope. The letter advises the customer to notify the Bank immediately if they have not moved. The customer’s address is not changed unless the Bank receives a completed Change of Address form.
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Dolly Nugent
CRCM
Opinions expressed are my own.

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#1074663 - 10/31/08 06:33 PM Re: Address Change Procedures ... comments? Dolly Nugent
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Fabulous!

I do have a "Returned Mail" policy that mirrors yours ...

Thanks for your comments :o)
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My opinions are my own, and not that of my employer.

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#1075639 - 11/03/08 09:38 PM Re: Address Change Procedures ... comments? WonderWoman
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
If you have good procedures in place for validating address changes AS THEY ARE RECEIVED, then you are automatically in compliance with the rules related to credit/debit cards.
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Dolly Nugent
CRCM
Opinions expressed are my own.

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#1077091 - 11/05/08 08:07 PM Re: Address Change Procedures ... comments? Dolly Nugent
Maytagman Offline
Gold Star
Maytagman
Joined: Jun 2008
Posts: 285
South
I do not agree. Please do correct me if I'm wrong...because your way would be so much simpler, but here is my take:

The red flags rules want you to consider the scenario that your request made in person was made by someone with a fake/stolen/modified ID, so that you can't rely solely on viewing ID at the time the request change is made (but viewing a signature card sounds pretty good though!). The picture and the signature on the ID could be changed to match the thief.

So, when an in-person customer shows ID (which might be fake) and requests an address change, then calls you 28 days later and asks for a new debit card to be issued to the new address, you still have to mail a letter to the old address to verify the validity of the address change (if you haven't already done so by that time). That belief is based on the part where it says that address change procedures can be relied on if they are done at the time of address changes as a standard and if the procedures meet the requirements of the regulation (which describes contacting the customer at the old address, but not simply viewing the requestor's (potentially fake) ID). Am I from Mars or is that correct?
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#1077281 - 11/05/08 09:41 PM Re: Address Change Procedures ... comments? Maytagman
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
can't this be risk based? We are such a small town/bank, I don't see the risk of this being any higher than someone trying to pose & withdraw money from an account ...
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My opinions are my own, and not that of my employer.

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#1077567 - 11/06/08 01:50 PM Re: Address Change Procedures ... comments? WonderWoman
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094

I think that it is sufficient to use a photo ID to verify the person before you is the accountowner - If you think you need something else, ask for his social security number (which is not usually not on photo IDs anymore) or ask a challenge question etc. It is so much easier to verify the validity of the address change at that time than worry about it twice (again when the card is ordered).
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Opinions are my own and not of my employer.

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#1079060 - 11/07/08 07:12 PM Re: Address Change Procedures ... comments? ahou
Compliance4521 Offline
Platinum Poster
Compliance4521
Joined: Jan 2007
Posts: 533
Washington
We verify all address changes before they are changed. Also to take it one step further, we were able to generate a report that will tell us when a card was reissued and an address changed occured within that last 30 days. We will utilize this report to determine if we had any reg. E claims, or returned mail. If we find the process we put into place in verifying address changes is not effective we will make changes within the Program.

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#1171007 - 04/27/09 10:45 PM Re: Address Change Procedures ... comments? Compliance4521
mmumm Offline
100 Club
Joined: Jul 2008
Posts: 163
Santa Cruz, California
We have a situation where the customer sent us a message via their secure online banking asking to change their address. Do other banks consider this like a "signature" since the customer has to sign into their online banking before sending the message, or do you still require an original signature?

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