| Obtaining Customer Address Changes and Use of P.O. Boxes |
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| Because scams have been perpetrated by establishing a bogus address or P.O. box for customer accounts, Compliance Supervisors Inc. would like to remind its clients of the importance of supervising customer address changes and of P.O. box use. CSI believes that a number of approaches can limit the potential for problems: |
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| Independent Monitoring |
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| A system for independent and separate from the sales and service functions generally provides for monitoring of account addresses and changes that can prove to be a successful supervisory and customer protection tool. |
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| Address Verification |
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| Our clients are encouraged to monitor address changes diligently and to verify them directly with the customer, either in writing to the existing and new addresses, in person or by phone. |
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| PO Boxes Discouraged |
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| Use of P.O. boxes for customer communications is generally discouraged by CSI. If it is approved, it should only be permitted with firm approval or verification by the customer. |
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| No Firm Addresses |
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| Generally, CSI advises its clients not to permit customer statements or confirmations to bear the address of the firm or any of its employees. |
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| C/O Addresses |
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| Registrants of the CFTC and Members of NFA should be attentive when opening accounts and when changing addresses that are established "C/O" (in care of) a third party. |
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| Exception Reports |
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| CSI believes that computer-generated exception reports are a useful tool in spotting trends among associated persons or branch offices, such as watching for multiple changes of address by any customer, many changes of address by particular associated persons or branches, or the use of the same address for unrelated customers. |
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| Protecting Blank Forms |
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| CSI advises its FCM clients that blank confirmations and customer statements be maintained in a secure location to prevent potential misuse. | |
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| DISCLAIMER | Copyright © 2002 Compliance Supervisors Inc.TM, all rights reserved. |
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