ARE THERE ANY ADDITIONAL REQUIREMENTS FOR ENTITIES THAT ISSUE DEBIT OR CREDIT CARDS?
Yes. The rules impose a duty on certain “issuers” of debit or credit cards, such as national banks, to establish and carry out reasonable policies and procedures to assess the validity of a change of address. Under the new rules, an entity should not issue a replacement debit or credit card if (1) the issuer receives notice of a change of address for the account holder and, (2) within a short period of time (30 days or so) thereafter, the issuer receives a request for an additional or replacement card for the same account. Once the issuer validates the address with the customer, it may issue the new card. To validate, the rules require that the issuer provide clear notice to the card holder at his or her former address and allow the cardholder the opportunity to confirm the change. In the alternative, the rules allow the issuer to use the policy and procedures set forth in its identity theft prevention program. CAN HEALTHCARE COMPLIANCE RESOURCES HELP US WITH THIS? In affiliation with
