Send Me No Mail

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Question:

We have a customer that does not want any mail (statements, IRS disclosures, promotions, etc.) to be sent to his or her residence and is requesting that the branch use its address for receiving all mail from the bank and then periodically he or she will stop by to pick it up. The former bank I worked for did not allow this. Is this anywhere in Reg or is it a bank policy?

Answer:

There is no regulation that would prevent your bank from holding all of this customer's bank-generated mail. However, there are a couple of things that should be considered. First, make sure that you do, in fact, collect and verify the customer's true street address. That's a requirement for CIP, of obvious value if you extend credit and could be needed for CTRs or SARs. That address, not the bank's, needs to be retained under the CIP regulations.

Second, you should get the customer's written request and authorization that you hold these communications. The authorization should include an agreement that nothing will be held more than XX days and will be mailed to the customer's address of record/shredded if not picked up in that time. Just to be safe, include a statement that the customer understands that communications will be considered delivered when available for pickup for Reg E and Z purposes and for other notification requirements.

First published on BankersOnline.com 8/06/07