Question: We have a member that does not have a good address or any other place that we can send mandated disclosures. Do we keep sending them to the bad address on file to meet our requirements?
Answer: No.
Members will occasionally vanish without a trace, although they may still continue to transact.
For these members, a diligent search for a new address should be made, but if no address is found, it is acceptable to notate the lack of a new address on file and withhold communications until a new address is found. The credit union should preserve evidence of the bad address, including any returned mail or bounced mail notices that justify your decision to cease communications.
If you have any other means to obtain a new address, such as a good phone number, you should continue to work these leads to re-establish contact. You may also discover a new address as part of an ongoing credit report monitoring related to a credit card or other line of credit.
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