So here’s a question: Is emergency card replacement or rush shipping dead as we know it? As my ID Insight team continues to pour over the FACT Act Red Flag and Address Discrepancy rules, it’s becoming more apparent that the old way of doing business just won’t cut it anymore.
The FACT Act says that if a customer changes his or her address then calls back within 30 days to request a replacement card, the credit issuer is required to “assess the validity of that address change” before sending out the card. Many small banks and credit unions routinely send letters to verify an address. If we’re reading it correctly, after the November 1 FACT Act compliance date arrives, banks that continue using the mail as an identity-verification system simply won’t be able to send the card until the customer receives -- and is given a reasonable period of time to respond to -- the letter.
We’re digging more deeply into this potentially critical piece of FACT Act language with our industry advisors and attorneys. Are the days of getting a replacement card in less than 24 hours gone?
What do you think? I hope you’ll share your perspective on this, either by posting a comment on this blog or dropping me an email at adam.elliott@idinsight.com.
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