Q. What is a CMRA?

A. A CMRA is a private business that accepts mail delivery from the Postal Service for others (addressee), holds it for pickup (in most cases a private mailbox ("PMB") or re-mails it to another address with payment of new postage. The traditional storefronts like MAILBOXES ETC., POSTNET, POSTAL ANNEX, and PAKMAIL are easily recognized as a CMRA.

There are also a number of non-traditional businesses that accept delivery of mail from the Postal Service for others, hold it for pickup, or re-mail it to another address. These businesses also usually offer other services to their customers like the traditional storefront CMRA but may not include mail, mailboxes, or postal in their name. Examples are:

1. Corporate Executive Centers (CECs) that generally offer customers a small suite or private office space, as well as shared office services such as mail receipt and re-mailing, message centers, fax systems, secretarial services, conference rooms, etc. Advertisements for these services are generally directed at small businesses or business persons who need office space and support services on a full-time or temporary basis due to the nature of their business. The CEC may provide these services through a small suite or private office covering a portion of an office building, or they may operate an entire building.
2. Storage businesses that offer their customer’s storage space and private mailbox services.
3. Businesses that offer mail forwarding and message services to customers that live and travel in recreational vehicles (RVs).

Q. Why did the Postal Service revise these rules?

A. The sole purpose of the Postal Service’s revised rule is to increase the safety and security of the mail, while at the same time protecting the interests of the sender and the addressee. The changes also clarify and update current CMRA requirements to be consistent with other current postal rules, policies, and requirements. The revised rule will benefit both businesses and consumers by reducing opportunities to use the mail for fraudulent purposes.

Q. What are the effective dates for compliance?

A. April 26, 1999	Regulations became effective.
May 6, 1999	All CMRAs should have filed a Form 1583-A with their post office.
August 26, 1999	The current customers of CMRAs must have completed the revised Form 1583 and it must be on file at the post office.
August 1, 2001	All CMRA customers must be in compliance with using the new address format "PMB and number," or the optional "#" and number (in certain conditions).

Q. Is the Form 1583 a "bootleg" request for information under the Paperwork Reduction Act of 1980? I have reviewed the form and it does not have an OMB approval control number for "information collection requests" under the Privacy Act of 1974.

A. The postal regulations, including the requirement for completion of Form 1583 or 1583-A, are valid. Federal courts have expressly held, in cases concerning the form, that the Paper Reduction Act (PRA) is not applicable to the Postal Service.

Q. Under what rule or law does the Postal Service have the authority to regulate the operations of CMRAs?

A. Postal Service’s authority to make rules is supported under Code of Regulations 39 CFR 111.1. By statute, the Postal Service is responsible for adopting regulations to ensure the security and safety of the mail.

Q. Where can I obtain Forms 1583 and 1583-A?

A. Forms 1583 and 1583-A are available on the World Wide Web at http://www.usps.com/ and at the home page click on Forms.

Q. What type of identification is required on Forms 1583 and 1583-A?

A. The CMRA and their customers must present two forms of identification, one with a photograph, when completing Forms 1583-A or 1583. Social Security cards, credit cards, and birth certificates are not acceptable forms of identification. The following are acceptable forms of identification: valid driver’s license or non-driver’s license state ID; armed forces, government, university, or recognized corporate ID; passport or alien registration card or certificate of naturalization; current lease, mortgage, or deed; voter or vehicle registration card; and home or vehicle insurance policy. Identification presented must be current. It must contain sufficient information to confirm that the applicant is who he or she claims to be and is traceable to the bearer.

Q. If there is more than one occupant of a PMB; does each occupant need to complete a Form 1583?

A. DMM Section 2.6a requires each addressee to complete and sign Form 1583. It allows only spouses to sign the same form but each must furnish two items of valid identification, one with a photo, and provide any required information that is different for either spouse in the appropriate box on the form. A firm may enter the names of other members of the firm receiving mail at the private mailbox in box 12 on Form 1583. The names listed must have verifiable identification and present it if the CMRA determines a need.

Q. What about people who are retired and spend all of their time traveling from place to place in a motor home or live on a boat. They do not have a permanent address.

A. If they live in a motor home or on a boat, the make, model and color of the vehicle, the license plate number and the state of registration would identify their permanent place of residence. The CMRA and its customer must make the decision on whether the information entered on the form meets the requirements. The CMRA has the responsibility to ensure that the applicant for their service presents valid documentation and accurate information to substantiate that he or she is the actual person they claim to be and is traceable.

Q. How does a CMRA verify a home address if they have international customers or even customers out of state?

A. If the customer is out of the country or state, the CMRA will have to mail the Form 1583 to the customer for completion. The customer must complete the form and sign it in front of a Notary Public. The Notary Public must witness the signature, verify the identification presented and confirm that the applicant understands and completes all of the required information, and mail the original Form 1583 to the CMRA (see block 15 on PS Form 1583). After reviewing the original Form 1583, if the CMRA doubts the validity or accuracy of the documentation or information submitted, the CMRA should request additional documentation to verify a home address or any other required information in the Form 1583. A CMRA should always decline service to customers if it is uncertain of documents or information presented to confirm an applicant is who he or she claims to be and is traceable.

Q. When is the CMRA required to submit the completed Form 1583 to the Postal Service?

A. It should be given to the Postal Service either the same day the form is completed and signed or the next business day. If the post office does not have a completed signed Form 1583 for an addressee receiving mail at the CMRA address; mail should not be delivered for that addressee.

Q. Is information in Form 1583 available to the public?

A. Information that is provided by a customer of a CMRA in Form 1583 is not available to the general public or to process servers. Information from Form 1583 may not be disclosed in response to an oral request. All requests from government agencies, including law enforcement, must be in writing. Information contained in Form 1583 regarding court order protected individuals may not be disclosed to any requester, including government agencies, except pursuant to the order of a court of competent jurisdiction. If a court order is received for information covered by a protective order, contact field counsel for advice.

Q. Can CMRA owners or managers accept accountable mail?

A. CMRA owners or managers can accept all accountable mail, except for Registered Mail, from their customers for mailing at the post office. This includes Certified Mail, COD, Delivery Confirmation, Express Mail and Insured. CMRA customers must take Registered Mail to the post office for acceptance.

There is no change in the current regulations on filing claims. The sender must file a claim for complete loss; and either the sender or the addressee can file for damage or partial loss. Although the CMRA presents the mail to the Postal Service for the customer, the customer is the sender. The CMRA should give receipts from the Postal Service to the sender, who must file any claim for indemnity.

The Postal Service is authorized through Form 1583 to deliver to the CMRA all accountable mail addressed to their customers with the exception of "Restricted Delivery." The CMRA customer must extend authorization to the Postal Service to deliver "Restricted Delivery" to the CMRA by signing in box #5 on Form 1583.

Q. Can CMRAs accept international mail from their CMRA customers for mailing?

A. CMRAs can accept international mail that bears the proper customs declaration as outlined in the International Mail Manual for each country from their customers for mailing. The CMRAs are responsible for taking such mail pieces to the post office for acceptance.

Q. Ninety percent of CMRA customer calls concern the revised regulation regarding the Private Mailbox (PMB) designation in the complete address. They assert the "PMB" is unnecessary, a stigma that unfairly portrays the CMRA customer as somehow unsavory, and reduces their ability to compete with the "big boys". The CMRA customers believe they are "entitled" to promote their business as being located at a "prestigious physical address" and Postal Service informing the "gullible public" otherwise will not protect them from "scams." It is also an inconvenience and the costs, thousand of dollars, associated with printing new stationery, brochures and business cards will put the small companies out of business.

A. "PMB" is an acronym for private mailbox like "PO Box" is for post office box. The "PMB" requirement only specifies the true identity of the address and does not portray those that use a CMRA in a negative (or positive) light. This comment seems to imply a public perception that CMRA customers are unsavory and therefore need to conceal this relationship with a CMRA. The Postal Service does not believe this to be true and doubt that CMRA customers believe it either. Accordingly, the Postal Service does not perceive that this rule should cause the asserted effect.

Current use of APT, STE, and other address designations by CMRA customers is misleading and does not identify the true location of the mail piece delivery. The Postal Service believes the sender, and the addressee receiving mail from a CMRA address, has a primary right to know the true identity of the location where mail originates or mail is delivered. The misleading use of a mailing address is not in the best interest of, and may cause harm to consumers and businesses.

This rule is consistent with the current policy of general addressing standards. PMB (private mailbox) simply specifies the true location of where a mail piece originates or is delivered, like APT (apartment), STE (suite), and PO Box (post office box) address designations. On August 16, 2001, the Postal Service published a final rule in the Federal Register that permits CMRA customers to use "PMB" or the alternative "#" as the secondary designation, under certain conditions. The preferred address format for the CMRA customers consist of:

If the four-line address cannot be used, a three-line format is acceptable. The PMB and number must be included at the end of the street address line. Exception: When the CMRA’s physical address contains a secondary address element (e.g., rural route box number, "suite," "#," or other term), the CMRA customer must use "PMB" in the three-line format. In this case, the following must be used:

The CMRA customer must use the four-line format if the primary delivery address of the CMRA contains more than 25 characters; the maximum number of characters allowed on the delivery address line is 32. Characters include the numbers, letters and spaces in the address. Example, the above delivery address of 10 MAIN ST STE 11 PMB 234 has a total of 25 characters.

The Postal Service recognizes CMRA customers will incur some out of pocket expenses and the inconvenience of notifying correspondents of the change in their address. Therefore, the Postal Service is allowing CMRA customers until August 1, 2001, to deplete existing stationery, to advise correspondents and to make any other needed changes to comply with the address requirement.

Q. How will a postal customer know when mail is from an individual or business renting a private mailbox (PMB) at a CMRA address?

A. Mail received with a "PMB" designation in an address informs the recipient that the sender is a private mailbox holder at a CMRA. To enable persons who receive mail with a "#" designation in an address, the Postal Service is establishing a toll-free number and Postal Service Web site that can be accessed to determine whether that address is the location of a CMRA where mail is delivered for private mailbox holders. Effective August 1, 2001, the Postal Service will implement the toll-free number (888-209-8726) which will allow postal customers to verify whether an address with a "#" secondary designation is an address located at a CMRA. Postal customers may also verify these types of addresses online through the Internet at http://www.usps.com, click on FIND ZIP Codes. On the ZIP+4 Code Lookup home page, enter the address, click on process and a response will be returned to confirm whether the address is located at a CMRA.

Q. How does a CMRA require compliance by their customers with the new address format (inclusion of PMB and number or "#" and number)?

A. The CMRAs inform their customers, during the application process, regarding all the customer’s responsibilities to continue or to start receiving mail services offered by the CMRA. The CMRA also provides its customer with the address to be used for the delivery of mail to the CMRA. If the CMRA customer refuses or fails to comply with Postal Service regulations governing the operations of a CMRA, the CMRA must terminate the relationship with the customers or deny the application of customers that refuse or fail to comply with regulations.

Q. The revised regulations call for the Postal Service to return all mail improperly addressed to a CMRA. Yet, the Postal Service will deliver mail to an apartment building that does not have an apartment or suite number. Is this a double standard?

A. No. There is a difference between mail with an improper address and that with an incomplete address. The Postal Service may return mail addressed to a CMRA customer with "suite," "apt," or any other improper secondary designator in the complete customer address other than "PMB" or "# " (under certain conditions). The CMRA has an obligation to ensure that all CMRA customers comply with this requirement. The CMRA must notify the customer and if the CMRA customer is not making the effort to comply, the CMRA must terminate the relationship with that customer.

Q. Is it true that the revised regulations require CMRAs to provide and pay for forwarding services that they currently do not have to provide?

A. Currently, CMRAs must provide forwarding services (re-mail) and their customers’ pay the postage required to re-mail to another address without any time limit on their responsibility. This requirement is appropriate and not new and has been in place since September 1960. The revised regulations actually shorten the required re-mail period to at least 6 months. This time period will shrink if CMRA former customers timely notify correspondents of their new address.

Q. Why does the Postal Service make the CMRA customers pay for certain services?

A. CMRAs are private enterprises that advertise and offer mail services of convenience to their customers. The Postal Service believes it is appropriate that the CMRA customer bear the costs associated with these services provided by the CMRA. Mail services offered by CMRAs are external to services offered by the Postal Service and is the CMRA customer’s choice. These costs should not be passed on to postal customers with higher postage fees.

Q. Why doesn’t the Postal Service apply the same mail forwarding policies for CMRA customers that it provides to its own post office box holders?

A. Post office box holders are customers of the Postal Service and, unlike CMRA customers, do not receive mail services of convenience external to the Postal Service. The CMRA and its customer agree (Form 1583) to payment of new postage to redeposit mail delivered to a CMRA. The Postal Service believes this requirement (existing since September 1960) remains appropriate and fair.

Q. Mail directed to businesses, hospitals, schools, apartments and even prisons are forwarded to the addressee without cost when they move. Why must CMRAs pay?

A. Unlike CMRAs, these institutions do not advertise or offer mail services of convenience to their employees, residents or other parties. Mail addressed to these institutions or to an individual by name or title at the address of the institutions is controlled by the institutions. Mail addressed to an

individual or business at a CMRA address is controlled by the addressee. The application, Form 1583, signed by the addressee and the CMRA confirms their obligation to affix new postage to redeposit mail delivered to a CMRA in the mails. Because this delivery is mail services of

convenience, it is reasonable to expect the CMRA customer to bear the costs, not the CMRAs.

Q. Why are CMRAs forced to receive mail that they cannot forward? CMRAs maintain that, under the requirements, they would have to continue to receive mail for customers for one year after a customer has moved. Many times they do not even know where a customer has gone, as customers frequently do not tell CMRAs where they have moved.

A. The CMRA is in business to accept delivery of all their customers mail and hold it for pickup or re-mail it to the addressee, prepaid with new postage. CMRA customers must provide the CMRA with their permanent address on the Form 1583, which CMRAs must substantiate. The CMRA can use this address, or another address specified by the customer, to re-mail after the agency relationship terminates.

The revised regulations require CMRA customers to file a revised application with the CMRA when any information required on Form 1583, including their permanent address, changes or become obsolete. The revised regulations require the CMRA to receive all mail for a former customer for at least 6 months after the relationship terminates. The CMRA may refuse - First-Class Mail only - for the former customer after the 6-month re-mail period and return it to the post office properly endorsed without payment of new postage.

Q. Since the revised regulations do not allow CMRAs to refuse the mail or return it until after 6 months, it will be tossed out, and the sender will think the piece has been delivered.

A. The CMRA’s inability to refuse or return mail without additional postage does not justify

destroying the mail. The Postal Service completes delivery when the CMRA receives the mail for the intended addressee. The CMRA must re-mail mail intended for the addressee (customer) for at least 6 months after the termination date of the agency relationship between the CMRA and addressee. The CMRA and their customers agree that all mail delivered to the agency will require new postage when re-deposited in the mails.

This re-mailing obligation need not be fulfilled if the CMRA customer provides written instructions to the CMRA that the mail (or specific types of mail) not be re-mailed upon termination of the relationship. This instruction may be provided in an internal service agreement between the customer and CMRA or by a separate document. Written instructions from the customer regarding the handling of this mail must not stipulate that the CMRA refuse mail or return it to sender, or hold the mail during the 6-month re-mail period and return it to the post office, or redeposit mail in the mails without new postage.

Q. Other addressees have the right to refuse mail, why can’t CMRA agents refuse mail for their clients? Is this a double standard?

The CMRA customer is the addressee, not the CMRA agent. It is a long-standing postal policy that only addressees can refuse mail, and the CMRA agent is not the addressee. Form 1583 on file at the CMRA and the post office, obligates the CMRA to accept delivery of its customer’s mail and hold it for pickup or re-mail it to the addressee, prepaid with new postage.

The revised regulations clarify the conditions under which the CMRA can refuse mail—namely the CMRA may refuse First-Class Mail only, for former customers, six months after the relationship terminates. When this happens, the CMRA endorses the mail and gives it to the letter carrier or returns it to the post office without payment of new postage.

Q. Are there other instances when a CMRA can refuse mail?

A. Yes! If the intended addressee is the CMRA itself, it may refuse the mail in compliance with DMM regulations regarding "refusal of mail." Some CMRAs apparently are under the misimpression that they can circumvent their obligation to re-mail material to current or former customers by marking the piece "refused" and depositing it in a collection box. This adversely affects a number of parties: the sender, whose mail does not reach the intended recipient; the addressee, who does not receive it; and the Postal Service, and its customers, which incur the costs of returning the piece to the sender.

Q. Why can’t CMRAs notify the post office immediately when a CMRA customer terminates the PMB?

A. The CMRA may notify the post office immediately when a CMRA customer terminates the relationship; however, the CMRA must again notify the post office in the quarterly report. The Postal Service will not require immediate notification and believe it offers no benefit for the CMRA to do so.

Q. Why must the CMRAs supply quarterly lists of customers?

A. We do not believe a quarterly list is unduly burdensome to CMRAs. We eliminated the requirement for CMRAs to immediately notify the Postal Service of customers who have terminated their relationships, and believe a quarterly basis will allow us to adequately monitor CMRA compliance and to determine potential fraudulent activity. An annual submission of the updated list of CMRA customers is inadequate because the average customer turnover rate at CMRAs is significant and recurrent.

Q. Do CMRA requirements apply to Corporate Executive Centers (CECs)?

A. A business is considered a CMRA when it advertises or offers to accept delivery of mail from the Postal Service for others, hold it for pickup, or re-mails it to another address, payment of new postage required. Generally, CECs meet this classification for all or portions of its operation. When a customer has a written agreement with the CEC that provides a private office and the customer is actually doing business at the address, full-time, and receive services such as, full-time receptionists service and live personal telephone answering service during normal business hours and voice mail service after hours and other business support services, this type of CEC operation would not be considered a CMRA. When CEC customers are not occupying a private office full-time, and are receiving other business support services offered by the CEC, on demand, and receiving mail services, this portion of a CEC operation is classified as a CMRA. The CEC must register as a CMRA with the post office by completing Form 1583-A and their customers must complete Form 1583 to authorize the Postal Service to deliver their mail to the CEC.