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#79277 - 05/09/03 07:09 PM CIP Question
DawgFan Offline
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In the CIP regs, I see references to a "Fleet Post Office" box. I am assuming that they are referring to your run-of-the-mill PO box, which can be opened for a nominal fee at your local US Post Office. Am I correct? Also, I am assuming that you can use this ONLY if they do not live at a physical address. In other words, if you have street address, the bank has to get it. Am I right?
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General Discussion
#79278 - 05/09/03 07:18 PM Re: CIP Question
Deena Offline
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I believe a Fleet Post Office Box is for military personnel serving in the Coast Guard, Navy, or Marines.
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#79279 - 05/09/03 07:48 PM Re: CIP Question
Nanwa Offline
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IMHO, I believe that people who get their mail sent to a P. O. Box (like me) also have a physical address. The bank needs to get the physical address to CYA for the reg, but they should also get the mailing address so notices and statements are not undeliverable. I do not receive mail at my physical address, so anything sent there would be returned.
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#79280 - 05/09/03 08:06 PM Re: CIP Question
GenerousLife Offline
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Correct! FPO = Fleet Post Office and APO = Air/Army Post Office. Check out the FAQ's on the "Supporting Our Troops" section of www.usps.com

These are military addresses for our servicepeople in other countries. This mail is handled through the U.S. Postal Service as opposed to being routed through that particular country's mail system.
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#79281 - 05/09/03 09:39 PM Re: CIP Question
Andy_Z Offline
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NewBanker has it. It may have changed, but in a very general, directional sense, APOs went to Europe (east of US) and FPOs went to Korea/Far East (west of US) for service members. That is simply their mailing address and in itself doesn't tell you where they are, but it allows a more efficient, faster and cheaper way to handle the mail and get it delivered to where that unit happens to be at the time.
It is not a PO Box as you know them.
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#79282 - 05/09/03 09:48 PM Re: CIP Question
John Burnett Offline
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Close, Andy.

FPO and APO are for Fleet Post Office and Army/Air Post Office, respectively.

The military address also includes AA, AE, or AP, which designate Armed Forces Americas, Armed Forces Europe, and Armed Forces Pacific, respectively. Generally, AE addresses will have an "east coast" ZIP code starting with "0" and AP will have a "west coast" ZIP code starting with "9".
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#79283 - 05/09/03 09:59 PM Re: CIP Question
Michelle D Offline
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There is one other group of people also may legitimately use FPOs and APO. Many "other" government employees who are stationed overseas, particularly in 3rd world countries receive their mail via an APO or FPO.

I had a friend that worked for the state department and when she was in Africa her mail went to an APO or FPO.

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#79284 - 05/12/03 02:02 PM Re: CIP Question
SMQ, CRCM Offline
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Between the lines
Did I see something to the effect that if we have one of these PO addresses and no other physical address for the individual, we should get the parent's address?
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#79285 - 05/12/03 02:06 PM Re: CIP Question
Andy_Z Offline
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I don't recall that, but it wouldn't be practical. Someone in the service 25 years could have an APO or FPO address and may not have parents alive.

These are the PO box addresses that you may use. An alternate is not required.
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#79286 - 05/12/03 02:24 PM Re: CIP Question
Elwood P. Dowd Offline
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or ...next of kin or of another contact individual... is an alternative, but military address is fine by itself.
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#79287 - 05/12/03 02:29 PM Re: CIP Question
SMQ, CRCM Offline
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Between the lines
Thanks, I thought I read something about this somewhere.
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#79288 - 05/12/03 02:40 PM Re: CIP Question
Andy_Z Offline
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The text is from page 32 of the final rules.

"The final rule therefore provides that a bank generally
must obtain a residential or business street address for a customer who is an individual because Treasury and the Agencies have determined that law enforcement agencies should be able to contact an individual customer at a physical location, rather than solely through a mailing address. Treasury and the Agencies recognize that this provision may be impracticable for members of the military who cannot readily provide a physical address, and other individuals who do not have a physical address but who reliably can be contacted. Accordingly, the final rule provides an exception under these circumstances that allows a bank to obtain an Army Post Office or Fleet Post Office box number, or the residential or business street address of next of kin or of another contact individual."
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#79289 - 05/12/03 03:10 PM Re: CIP Question
RebekahL CRCM Offline
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Big Sky Country
Quote:

FPO and APO are for Fleet Post Office and Army/Air Post Office, respectively.

The military address also includes AA, AE, or AP, which designate Armed Forces Americas, Armed Forces Europe, and Armed Forces Pacific, respectively.




These posts bring back some sweet memories of writing to my fiance (now husband) when he was aboard the USS Blue Ridge. All those times I wrote "FPO AP 96628-3300" on perfumed letters with an upside-down stamp in the corner will forever live in my memory. E-mail may be convenient, but it will never compare to a handwritten love letter.

John - welcome back! Did you have a wonderful vacation?
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#79290 - 05/12/03 03:32 PM Re: CIP Question
John Burnett Offline
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Yes, Rebekah, it was wonderful, in spite of the mountain of (a) snailmail, (b) spam, (c) legit email, and (d) unread BOL entries. Thank you.
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#79291 - 05/12/03 04:59 PM Re: CIP Question
DawgFan Offline
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Thanks, everyone, for your insights. Let me change the topic of conversation to another CIP issue. How do you all plan to satisfy the customer notice requirement? Do you plan to put it on your applications for disclosure? Do you plan to use a lobby notice? I'd appreciate your thoughts.
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#79292 - 05/12/03 05:24 PM Re: CIP Question
Walleye Woman Offline
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We put up a lobby notice last fall and sent out statement stuffers.
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#79293 - 05/12/03 07:53 PM Re: CIP Question
GreatBlue Offline
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Quote:

How do you all plan to satisfy the customer notice requirement?




We haven't gotten that far yet, but I would think it would have to be both a lobby notice and on the applications. Assuming you can demonstrate that all applications for new relationships would have an opportunity to see the branch notice, then you could probably stick with that. However, if you mail out applications, or a loan officer takes applications out of the office, then you'd need it on the application forms as well.
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#79294 - 05/12/03 08:54 PM Re: CIP Question
Anonymous
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What about minor accounts? One trainer said that we would verify the identy of the "person opening the account" for the minor. Another trainer said that we would no longer be able to open accounts in that manner. I find that really hard to believe?


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#79295 - 05/12/03 09:13 PM Re: CIP Question
DawgFan Offline
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The answer to your question hinges on who the customer is. The definition of customer in 103.121(a)(3)(i)(B)(1) says a customer includes "An individual who opens a new account for an individual who lacks legal capacity, such as a minor."
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#79296 - 05/12/03 09:47 PM Re: CIP Question
Anonymous
Unregistered

More than you'll ever want to know about Fleet PO Boxes -- from the USPS site:

Naval stations are different from other Department of Defense installations in that they receive fleet post office (FPO) mail for the ships assigned to that particular base. These ships can be either in port, at sea, or laid up for repairs. This mail is received from the appropriate mail processing center already containerized by ship.

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#79297 - 05/12/03 10:24 PM Re: CIP Question
Miss Kitty Offline
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Inuyasha -
We have created patriotic tent notices for each desk/work station that states our Customer Identification Policy.

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#79298 - 05/12/03 10:51 PM Re: CIP Question
Bear Collector, CRCM Offline
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District of Columbia
Quote:

... a bank generally must obtain a residential or business street address for a customer who is an individual.....



It is our current policy not to accept a business address as a contact adddress for an indvidual - all individuals must have residential street addresses unless they live in a rural area where such addresses do not exist. Is this saying that you must have a street address no matter what, or that either a street or a business address is acceptable? If it is the latter, then am I correct is assuming that if your policy is more stringent than the regulations, then you may follow your policy?
BC
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