**USPS Finalizes CMRA Ruling

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The U.S. Postal Service published a new rule yesterday on the addressing requirements for individuals or small mail-order companies that want to get their mail at commercial mail receiving agencies such as Mail Boxes Etc.


The USPS will require CMRA private mailbox holders to include either a "PMB" designation or the pound sign on their mailing address to signify it as a CMRA mailbox, rather than an apartment or suite number. No designation is currently required.


Though the rule is effective immediately, box holders have until Aug. 1, 2001 to comply.


The secondary address designation is intended to protect consumers, since many private mailbox holders have used a suite or apartment number along with the street address of the CMRA, implying to senders of mail that the box holder maintained a physical presence at that location, said the USPS, Washington.


These addressing practices created the opportunity for fraud schemes, the USPS said. For example, consumers who want to donate to local organizations or buy from local businesses might mistakenly think they are doing so when they respond to an out-of-state organization or firm with an address at a local CMRA.


The new designation will ensure that the public knows the address is not a physical location and therefore will discourage fraudulent or deceptive practices, the USPS said.


"Our intention was to provide the public a means to be completely informed whether an address represented a physical location," said Mike Spates, manager, delivery operations, USPS.


The postal service filed this ruling in the Federal Register in March, asking for public comment. It differed from the original ruling, announced in March 1999, which required CMRAs to include the PMB designation without the option of using the pound sign. That rule was never implemented.


The USPS received 20,456 comments. Most of them -- 20,153 -- supported the rule.


Twelve comments opposed the requirement for a secondary address designation and questioned whether there were appreciable fraud statistics to support the need for CMRA regulations. Many of these mailers, who represent small-business groups and some CMRA private mailbox holders, asserted that some consumers might be discouraged from doing business with CMRA mailbox holders, perceiving those businesses as "unsavory."


The other 291 comments urged the USPS to keep the original plan to use the PMB designation without the alternative of the pound sign. These generally were from groups representing consumers, such as state attorneys general, an association of state charity officials and an association of financial crimes investigators, as well as address list maintenance vendors, an association of presort mailers, major mailers, individual consumers and private mailbox holders.


The pound sign may confuse mail senders, who might think it represents a physical location, they said. They were skeptical that the use of "PMB" would harm small businesses. Some also thought the new rule would harm consumer protection interests.


In its ruling, the USPS said it understood those concerns. It said the agency and the CMRA industry would implement these initiatives:


• Educate the public on the meaning of the PMB and pound sign designations. The postal service is prepared to work with the CMRA industry and consumer groups to design these materials and the best means to distribute them.


• The USPS will establish methods (a toll-free number and/or the USPS' Web site) that can be accessed to determine whether a street address is the location of a CMRA. This will let people who receive mail with a pound sign designation determine whether the sender is a CMRA box holder.


• The USPS will continue working directly with the CMRA industry to address continued concerns. The industry is working with the postal service to ensure implementation of the postal standards concerning delivery of mail to CMRAs.


• The Postal Inspection Service has improved data collection regarding the number of cases involving the use of off-premises delivery services, including post office boxes, for fraud.
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