Question of the Week: Members with No Address

Question: 

Under the Bank Secrecy Act’s (BSA) Customer Identification Program (CIP) requirements, what address should we obtain for a member who lives in a rural area and does not have a residential or business address? For example, is a rural route number acceptable as the member’s address?

Answer: 

According to FFIEC BSA guidance, if a customer lives in a rural area and does not have a regular street address, the credit union may use the address shown on the customer’s mailbox along the rural route. A rural route number is acceptable because it helps identify the general area where the customer lives.