Financial Account Records
Safe at Home is Minnesota's address confidentiality program for people who fear for their safety. It is administered by the Office of the Minnesota Secretary of State. Participants of the Safe at Home Program have extremely high security needs and are assigned an alternate address that they can legally use as their address for all purposes (Lot [XXX], PO Box 17370 Saint Paul, MN 55117). This allows them to keep their physical address confidential to help ensure their safety. A participant’s assigned PO Box address is the address financial institutions must accept and use for financial account records.
USA PATRIOT Act Exemption
A Safe at Home participant cannot be required to disclose his or her home address for financial account records.
The United States Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) has acknowledged the need to protect victim anonymity. On November 3, 2009 FinCEN authorized an exemption for participants in address confidentiality programs (ACPs) from the usual USA PATRIOT Act requirement that people provide their actual residential address for bank account records. Therefore, financial institutions must not require a Safe at Home participant to disclose their home address in order to be Customer Identification Program (CIP) compliant. Go here to view the federal administrative ruling.
For CIP compliance, instead of the participant’s home or business address the financial institution is required to collect the street address of the Office of the Minnesota Secretary of State. To obtain this address call 651-201-1399.
Note: The Minnesota government address used by financial institutions is not to be disclosed to Safe at Home participants nor used by Safe at Home participants. It is provided to financial institutions in order for them to meet federal guidelines. Any mail sent to the physical address provided will be returned to sender. Financial institutions must send mail to a participant’s assigned PO Box address.
For purposes of a home mortgage, a participant must disclose the address of the home to the lender. The participant will provide a form to the lender that is given to them by the Safe at Home office. The notice will require the lender to privatize the mortgage record and will prohibit the sharing of their location information without signed consent from the participant. The lender must use the participant’s assigned PO Box address for mailed correspondence.
For loans other than a home loan, a Safe at Home participant cannot be required to disclose their real home address. Minnesota law requires all public and private entities to accept and use a participant’s address as their home address.