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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"It is natural to give a clear view of the world after accepting the idea that it must be clear." - Albert Camus