Compliance Alliance Q&A 10/27/2020

Q: FCRA 222.91 - Section about address changes and card issuance. Do we only care of address changes made first followed by card request, versus card ordered and then address change?


A: So while the regulation and the guidance only refer to times when a debit or credit card is ordered shortly after a change of address is requested, it is highly advisable and a best practice to validate addresses in general because of the potential identity theft and red flag concerns.
Address validation requirements (12 CFR 222.91(c)). A card issuer must establish and implement policies and procedures to assess the validity of a change of address if it receives notification of a change of address for a consumer’s debit or credit card account and, within a short period of time afterwards (during at least the first 30 days after it receives such notification), the card issuer receives a request for an additional or replacement card for the same account. In such situations, the card issuer must not issue an additional or replacement card until it assesses the validity of the change of address in accordance with its policies and procedures. 

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