We received an email from American Express today with the old refrain of "The Feds require a physical address". As full-timers, this is always an issue, it seems. (I was just recently refused coverage through the Marketplace for the same reason, but that's a different issue.)

So, have other SKPs started getting the same kind of communication? Is there actually a federal regulation that has now required this? Is there a prescribed course of action? Should we anticipate that other card issuers are soon to follow?

Thanks in advance for any ideas. The text of their communication is below.

George & Geri, SKP 89203

~~~~~~~~~~~~~ SNIP ~~~~~~~~~~~~~~~

Federal guidelines require us to maintain a physical address for our customers. We are writing because we recently discovered that we do not have an updated physical address on file for your Card account(s), and request that you provide it to us by March 31, 2016.

We need a physical address for your Card account(s)

For your reference, your physical address is the street address where you resideand cannot be a P.O. Box or mail collection agency address. For the purpose of managing your Card account(s) you may have multiple addresses on file with us. However, one of those addresses must be a physical address.

How to provide your physical address to us

You can provide us with your physical address by logging into your Card account(s) at americanexpress.com or by calling the number on the back of your Card. Unfortunately, if we do not receive this information by March 31, 2016, we will have to suspend your Card account(s) and charging privileges until the information is provided.

If you have any questions or need assistance, please contact us by logging into your account online or by calling the number on the back of your Card.

We appreciate your assistance and thank you for your continued Card Membership.

Sincerely,

American Express Customer Care

~~~~~~~~~~~~~ SNIP ~~~~~~~~~~~~~~~

If you use Escapees RV Club mail forwarding there shouldn't be an issue. Our address was always good for 16 years of full-timing with all kinds of financial institutions and credit cards.

Amex does not like PMBs at Escapees. All that they wanted was a physical, residential address of which my daughters was accepted.

They knew that it was her address and were fine with it being across the state from us.

Are you using an Escapee provided address? There have been some changes in the "Patriot Act" that is causing so much problem for us because of the issue of tracing funds of imported terrorist activities, as an accidental side effect. If it is like many such situations you can give them an address of a relative who is fixed and use your mail service address as the "mail to" address for communication.

"Is there actually a federal regulation that has now required this? Is there a prescribed course of action? Should we anticipate that other card issuers are soon to follow?"

Yes, to a degree. The US Patriot Act, section 326 requires all federally regulated financial institutions to implement a CIP (customer identification program). This requires the financial institution to verify the identity and residence of all new customers. The intent of this was to prevent money laundering through straw accounts. However, the same act includes a provision for people who have no physical residence, to provide a physical address of a family member or close friend. Their address is used for CIP verification only, your mailing address should remain as the address of record for the account.

Even though this section of the act clearly states it applies to new accounts, and it provides an alternate for physical addresses; the Feds say their requirements are the minimum and they leave it up to each financial institution to decide if they want to implement more stringent requirements. So after being audited, some banks are making their own rules apply to more than the original act required.

This law was passed all the way back around 2005. But as with most new & complex federal laws it takes forever to issue the detailed operational rules and additional years for the impact and understanding to spread through the targeted industry.

This same issue has been discussed here many times over the last several years, involving several different banks & brokerage firms.

Edited February 21, 2016 by Jim2

I have several addresses on file with Amex. One is the house where my Son's family lives but I have had no trouble using myhomeaddressinc in Emery, SD, either. Even General delivery in Sequim works as long as I give the street address of the post office that handles it.

We just provided my sisters address for our CC thru Alliant Credit Union. They of course know were fulltime because they hold the loan on our MH

Find a relative and with their permission use their address. While it may seem like an intrusion on our lifestyle, it is one thing we chose NIR to make an issue

Just checked our account online. For one Amex card, which already had an alternate address is a S&B we were good to go. For the Costco Amex card, I just had to add the same physical address as an alternate and was finished.

Easy enough.

Thanks for all the responses. I was able to get an "alternate address" into their system and hopefully this issue will go away.

  On 2/21/2016 at 9:40 AM, nana25k said:

We just provided my sisters address for our CC thru Alliant Credit Union. They of course know were fulltime because they hold the loan on our MH

 

Very interesting. I JUST (yesterday) got a credit card from Alliant (a newly issued card - did not have one there before) and they did not hesitate on the Escapees Livingston address. In fact, in the years we have used Alliant they have never questioned the Escapees address. Nor has Merrill Lynch - although my financial consultant there may have intervened on that and I don't even know that they did so.

  On 2/22/2016 at 11:40 PM, Jack Mayer said:

Very interesting. I JUST (yesterday) got a credit card from Alliant (a newly issued card - did not have one there before) and they did not hesitate on the Escapees Livingston address. In fact, in the years we have used Alliant they have never questioned the Escapees address. Nor has Merrill Lynch - although my financial consultant there may have intervened on that and I don't even know that they did so.

Don't know Jack. We received the card the same time we processed the MH financing 2 years ago. They don't mail anything to that address except the card.