Review New CIP Address Requirements

CUNA’s Front Line newsletter
May 7, 2010 | COMMENTS

Your staff can't accept post office box addresses when opening new accounts for members, correct?

For the most part, that's true. Bank Secrecy Act (BSA) regulations governing customer identification programs (CIP) require a credit union to obtain a residential or business street address at account opening. If the member doesn't have a residential or business street address, the regulations permit the member to provide a “residential or business street address of next of kin or of another contact individual.”

But how can you open new accounts for members who participate in address confidentiality programs (ACP)?

Thirty-one states have enacted laws establishing ACPs. These programs provide substitute addresses for victims of domestic violence, sexual assault, and stalking, and help participants keep their physical addresses confidential. ACP participants receive post office box addresses where mail is received on their behalf. The mail is then sent on to the participant's actual address. Authorized state entities, typically the secretaries of state, serve as designated agents for the participants.

Unfortunately, until recently, these programs presented a conundrum for credit unions and other financial institutions attempting to open new accounts for ACP participants. Credit unions weren't in compliance with these rules if they accepted ACP post office box addresses when opening new accounts.

Fortunately, earlier this year the Financial Crimes Enforcement Network (FinCEN)—the U.S. Treasury agency that collects and analyzes information about financial transactions to combat money laundering and other financial crimes—issued an exception to this requirement. The exception treats ACP participants as not having a residential or business street address, and the state entity serving as the designated agent of the participant now acts as “another contact individual” for the purposes of complying with the regulation.

When opening new accounts for ACP participants, member-contact staff needs to collect the street address of the ACP sponsoring agency to meet the address requirement. Staff should also review your credit union's CIP policy, to be familiar with this new exception and with related policies and practices. Remember, also, not to accept post office box addresses from members who aren't ACP participants.

The author, Chris Collver, is senior regulatory and legislative analyst for the California and Nevada Credit Union Leagues. Contact him at 800-472-1702, ext. 6053, or at chrisc@ccul.org. This story first appeared in CUNA's Credit Union Front Line Newsletter and is reprinted with permission.