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Our bank procedures require us to obtain a customer signature or online authentication before we update a customer’s address. However, we have a customer with a delinquent commercial loan who appears to be avoiding our bank. The mail that we send to the customer’s address on file keeps being returned as undeliverable. We have obtained the customer’s new address. Can we update the address without obtaining the customer’s signed authorization? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Our bank procedures require us to obtain a customer signature or online authentication before we update a customer’s address. However, we have a customer with a delinquent commercial loan who appears to be avoiding our bank. The mail that we send to the customer’s address on file keeps being returned as undeliverable. We have obtained the customer’s new address. Can we update the address without obtaining the customer’s signed authorization?

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Yes, we believe that you may update the address on file without obtaining the customer’s authorization.

In fact, it is advisable to discontinue loan periodic statements to an address that you know is incorrect, in order to prevent the customer’s statements containing financial information from falling into the wrong hands.