ID Theft Red Flags FAQ IIIA1 – Can a card issuer rely upon the US Postal Service’s change of address procedures to validate a change of address for purposes of the Card Issuers’ Rules?

Compliance > Lending > FCRA
Q:  Can a card issuer rely upon the US Postal Service’s change of address procedures to validate a change of address for purposes of the Card Issuers’ Rules?
 
A:  The fact that a card issuer received a change of address notice from the US Postal Service is not sufficient to satisfy the validation requirements of the Card Issuers’ Rules. A card issuer that receives a notice of a change of address from the postal system regarding a cardholder’s address, and, within at least 30 days, a request for an additional or replacement card, may not issue the card unless it has validated the cardholder’s address using one of the procedures set forth in the Card Issuers’ Rules
 
 
ADDITIONAL INFORMATION:
This information was obtained from the Interagency FAQs for Identity Theft Red Flags and Address Discrepancies - https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20090611a1.pdf
 

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