Bank using own address.

    

0 We offer a sen/ice called holdmail We don't send you
statements/letters/etc. You sign a waiver against right to receive them.
We hold them for collection. On our system, we used to print out all
the advices (transaction accounting), and we needed a way to
physically separate the hold mail accounts from normal accounts.
They'd then know to put this to the side Everything needed to be
printed, so this would tell us not to deliver them. That was happening
before I even started. Then at some point, there was an EU legislation
With requirement for all outgoing transactions to include minimum
details, including address, etc. Relatively recent, maybe within 5
years. So now we had both a tech issue and a compliance issue. From
tech side, I have holdmail listed in core banking system in address
spot. SWIFF would then also say holdmail in address spot. We knew
there was an issue I remember having a meeting on this Back then,
this was a customer service issue, so my involvement was because of
my IT knowledge Now this falls under operations. So no mailing
address was in the system. We kept the address in the paper file, but
it wasn't on the elect system. --saw holdmail as a sen/ice we
offer saying we shouldn't be giving out their address on the 
message. As a privacy issue, that we agreed to hold their address. I
saw it as a practical matter that we just couldn't get their mail to them.
So from lT perspective, we had to do changes to system.--

    

 

suggested we give the address here, and we have an address on file if
it's needed. 50 bank's address was used against all noldmail clients.
No other non-holdmail clients used the bank's address. Only holdmail.
I took the opportunity to change the way the advices came out. We
stopped printing them. lcnanged it so that they wouldn't be printed
out. We also had a lot of "Care of" addresses. Those also became the
bank's address. it was just done to make life easy to avoid opening the
files and deciding what went Where. They had little brackets next to
them to say who they were "care of." They were all "care of" the bank
and various departments. Effectively it was a different way of doing
holdmail. Many were related parties, like if my mother did it since I
worked here. The decision making was stupid. At the time. it was
Andreas' decision. I was saying it was a stupid decision. it's an
address, but it obviously went against the spirit. So we moved
forward. JPMC then made a complaint about so many clients having
our address, so it came up again. We ended up meeting again and i
came up with idea to put the registered address because we had it in
our database. I could pull it out and make it fit in the fields, and we
could put it in instead of bank's address. It was the only address we
had that we could do quickly. For personal account, we wouldn't have
had a registered address, so customer service had to contact them to
get info. Were also some registered addresses that came up for Syria
and Iran. Not many, but a handful of not very active accounts. Sol
pointed that out and was told to leave it as bank's address. Va ue
recollections, but pretty sure it involved fi
Don't remember who told me to leave that, but it was one of
those 3. was worried we had Syria/Iran accounts. I think this was iust
bad decision making. Not a grand conspiracy. We might have marked
them for no debits or credits, not sure. Did not put this into email. But
if we opened new accounts, it would be masked. if bank opened a new
account with registered address in Syria/lran, would put bank's
address. -- i don't know for sure that it was
done, but there was a memo to do it that way. So if an account came
in With Iran address, we'd put in bank's. Idon't think any transactions
were actually conducted out of those accounts.
- Why would you open an account for an entity you didn't do
business for

- Most of the existing accounts were fairly inactive. Don't

know about new ones.

0 We 5th have ho'dmai' accounts Don't reaHy know why chents want
them We have a culture of secrecy, Mke Swiss bankan model Peop'e
don't want on to know the bank with on