The Domestic and Sexual Violence Victim Address Confidentiality Act (23 Pa.C.S.A. §§ 6701 et seq) created the Pennsylvania Address Confidentiality Program (ACP). The ACP provides an important service to victims of domestic violence, sexual assault and/or stalking by providing a legal substitute address for victims who have moved to a new location unknown to their perpetrator. State and local government agencies are required to use the ACP substitute address as the participant’s legal address. Banks are now required to accept the substitute address, allowing participants to keep their physical address confidential. This letter will explain the requirements of the Financial Crimes Enforcement Network (FinCEN) ruling.
An ACP participant’s account profile must indicate the customer’s ACP substitute address, including their ACP number. All correspondence, including any potential legal correspondence, must be sent to the customer’s substitute address. All ACP participants are provided a laminated authorization card, which includes their complete ACP substitute address. A sample copy of the card is attached to this letter.
The ACP substitute address is:
(Participant’s ACP #)
PO Box 2465
Harrisburg, PA 17105-2465
The only time you may use an address other than the ACP substitute address is for the Customer Identification Program (CIP) requirement. On November 3, 2009 the United States Department of the Treasury, Financial Crimes Enforcement Network (FinCEN), authorized an exemption for participants in address confidentiality programs (ACPs) from the usual requirement that people provide their actual residence address for bank account records. The letter specifically states:
"A customer who participates in a state-created ACP shall be treated as not having a residential or business street address and a secretary of state, or other state entity serving as a designated agent of the customer consistent with the terms of the ACP, will act as another contact individual for the purpose of complying with FinCEN's rules." ~ US Department of Treasury, Financial Crimes Enforcement Network, letter dated November 3, 2009.
Pennsylvania’s ACP is administered by the Pennsylvania Office of Victim Advocate (OVA). In accordance with the FinCEN Ruling, OVA will serve as another contact individual for the purpose of the customer profile address for participants in Pennsylvania’s ACP, allowing banks to comply with FinCEN’s rules without obtaining a participant’s residential address. The following address, including the ACP#, must be documented in the record as the customer profile address for an ACP participant banking customer:
Office of Victim Advocate
1101 South Front Street, Suite 5200
Harrisburg, PA 17104
No banking correspondence should ever be sent to this address. No correspondence for ACP participants will be accepted at this address. This address is only to be used as the customer profile address for the ACP participants’ banking records. The OVA’s address is only to be used for internal banking purposes.
The Office of Victim Advocate will not be responsible for any collections actions.
Thank you for your cooperation in helping to keep ACP participants safe. If you have questions about Pennsylvania’s Address Confidentiality Program, please contact us at 1.800.563.6399.