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The New Regulations

all future mail. Thus, an address would have

to appear as

The new regulations, printed in the March

John Doe Enterprises

25 Federal Register, informed CMRA operators

PMB 401

that by June 24, 1999, they must instruct all

123 Main St.

their box renters to fill out, sign, and have

Everytown, Home state ZIP code

notarized a new Form 1583. The box renters

then must submit the form with "two items

of valid identification; one item must contain

According to the regulations, after a prob-

a photograph of the addressee." The identifi-

able October 24, 1999, deadline, all mail

cation must show "the applicant's signature

addressed to a box renter that does not have

and a serial number or similar information

the required PMB in the correct place will not

that is traceable to the bearer."2

be delivered and will be returned to the

sender. (The new postal regulations are

Corporate and business box renters must

ambiguous, suggesting several possible dates

disclose not only the address and date of for-

on which the regulations will take effect.)

mation of the enterprise but also the names

and home addresses of the enterprise's offi-

The new regula-

cers. Those box holders must also indicate

tions will foist

Opposition to Regulations

whether the box address will be used for

doing business with the "public." The Postal

enormous costs on

Service offers no definition of "public." For

The U.S. Postal Service cannot argue that

some 1.5 million to

example, if the box renter is doing business

the new regulations were drafted in response

2.5 million private

only with other businesses, does that consti-

to the demands of CMRAs or their cus-

tute doing business with the "public"?

tomers. The USPS opened its initial manda-

commercial mail-

In the past, most CMRAs were required to

tory 30-day comment period on August 26,

box holders, which

hold the box renter's Form 1583 in the event

1997, and opened an additional 30-day peri-

include many of the

that postal inspectors might need it for a

od on November 24, 1997.

criminal investigation. The new rules require

Interestingly, the timing of that final com-

country's smallest

duplicate forms, which include private infor-

ment period coincided with the dramatically

businesses.

mation about the renter, to be sent to the

disproportionate seasonal demand for the

Postal Service. That will allow the USPS to

services of the affected CMRA operators.

maintain a nationwide database of all CMRA

Many of those operators generate up to one-

box-renting customers, along with identify-

third of their annual revenues during the

ing numbers, home addresses, and home

one-month period preceding Christmas.

phone numbers of those using boxes for

During this time, the resources of those oper-

business.

ators are overwhelmed in meeting the needs

The new regulations also give the CMRA

of their customers.

operators the authority to collect and main-

Despite such extremely poor timing, the

tain photocopies of the identification forms

Postal Service reported in its March 25 Federal

provided by the box renter, an authority not

Register posting that 727 CMRA operators

granted to the Postal Service itself under its

and 7,365 of their customers found time to

own privacy rules for P.O. box renters.

lodge their opposition to the regulatory revi-

The March 25 rules require CMRA box

sions.3 Four CMRA franchisers and trade asso-

renters to contact every person or entity that

ciations, as well as a member of Congress,

has sent them mail in the past and that

lodged additional opposition. Conversely, a

might send them mail in the future and

total of 10 comments was received in support

advise them that the acronym "PMB" (Private

of those revisions. Proponents of the revisions

Mail Box) must precede the renter's box

included large companies, financial institu-

number on a separate line in the address on

tions, trade associations of mailers (direct

3