Starting with the implementation of Phase 2e (Full CAIS), Industry Members must report one mailing address associated to the FDID in the ‘ADDRESS1’ value of the addrType field. If an FDID is based on a relationship that represents multiple customers with different addresses, and the Industry Member does not store an address for the relationship, but maintains the addresses at the customer level, what address should the Industry Member report to CAIS for ‘ADDRESS1’?
If no address is stored at the FDID level, the Industry Member must choose one mailing address associated with one customer and report it as the mailing address associated to the FDID. Industry Members have the ability to report an additional three addresses associated with the FDID via the ‘ADDRESS2’, ‘ADDRESS3’, and ‘ADDRESS4’ values.
Although a specific methodology is not prescribed for choosing which address(es) to report to CAIS for the FDID, any methodology must be applied consistently by the Industry Member. In addition, the Industry Member must be consistent in its approach and methodology for populating the ‘ADDRESS2’, ‘ADDRESS3’, and ‘ADDRESS4’ values, if populated. Please see FAQs Q44 and Q45 for more information.
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