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We’ve always been told by our examiners (FDIC) when someone changes their address and is not face to face prior to the address change we needed to send a letter confirming the address change and requesting their signature. This confirmation letter is sent to both the new and the old address and requires their signature, which ensures no identity theft is present in the situation.
Do you feel that is still true?
Thus, to prepare for the EMV rollout our institution would like to give our customers a more convenient option of changing their address through DocuSign if they are not able to come into one of our branch locations. DocuSign would offer a secure link using a code for the customer. We would have access to reports that can track the customer IP address and can see their electronic signature.
I’ve searched the regs and cannot find anything that would state we wouldn’t be able to complete them this way. Assistance is appreciated!
Everyone’s thoughts???
Thank you!We are not aware of any formal guidance that would require you retain that process. I assume it was the opinion of the examiner and what that examiner deemed to be a best practice.
If you look at 12 CFR 222.91 it outlines rules for address verification if it is also followed by a request for an additional card; you can also meet that requirement by verifying the address when the change is requested which I believe is a prudent approach. However, there is not a signature requirement. You will need to determine if the new process will complies with the requirements in 222.91 and your policy and procedures.
I’m not sure how many examiners you have heard this from, but it may be worth your time to proactively have a conversation with your examiners rather than trying to defend it later which might be more contentious. If they insist a signature it is required they should be able to show you the requirement.
Do you feel we would need to at a minimum be sending out a confirm letter to all customers who change their address by any other means than in person?
Yes, I think your best course of action to comply with the requirements would be to verify/send the notice at the time of the address changes rather than waiting for a request for new or replacement cards. By automatically notifying the customer you eliminate the need for monitoring those changes for at least 30 days for a request for a new or replacement card and then notifying after such receipt.
Form of notice (12 CFR 334.91(e))
Any written or electronic notice that a card issuer provides to satisfy these rules must be clear and conspicuous and provided separately from its regular correspondence with the cardholder.Here are the FDIC exam procedures: https://www.fdic.gov/regulations/compliance/manual/8/viii-6.1.pdf. Change of address begins on p. 6.35.
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