Identification Number:
Intended Audience:RCs/ARCs/ADs/FOs/TSCs/PSCs/OCO/OCO-CSTs
Originating Office:DCO OPSOS
Title:Comerica temporarily waives the signature requirement under the consent-based process during the COVID-19 Pandemic
Type:EM - Emergency Messages
Program:Title II (RSI); Title XVI (SSI); Disability
Link To Reference:See References at the end of this EM
Retention Date: September 4, 2021

A. Purpose

This Emergency Message share updates on the Direct Express (DEX) consent-based process signature requirement.

B. Background

According to GN 02402.007I, the consent-based process should be used when a cardholder has attempted to resolve his or her DEX account issues on his or her own, but has been unsuccessful. The cardholder must be present in the field office (FO) before the technician can use the consent-based process on their behalf. After the technician successfully verifies the identity of the cardholder, he or she must review and sign a consent form (Schedule A). This consent form is only valid for three months from the date of signature.

C. Temporary Signature Waiver

Due to the COVID-19 pandemic and limited in-person service in FOs, Comerica Bank has agreed to temporarily waive the signature requirement under the consent-based process. Under this agreement, SSA and Comerica will share DEX cardholder banking information without requiring a signed consent agreement. FO technicians handling incoming DEX related calls that require dire assistance should continue to verify the cardholder’s identity using the procedures listed in GN 03380.005B.2 prior to contacting Comerica’s ACH line. If the cardholder is a representative payee, be sure to fully authenticate the identity of the beneficiary/recipient, as well as the representative payee. The passphrase is still required when calling Comerica’s ACH line.

The requirement of obtaining a signed consent form will resume once FOs reopen to the public.

Direct all program-related and technical questions to your regional office support staff.

GN 02402.0007 Direct Express Debit Card Program
GN 03380.005 Verifying Identity of Persons Making Access Request
TC 16001.020 Identifying the Caller for Direct Deposit or Direct Express
TC 16001.025 Handling Fraudulent Direct Deposit and Direct Express Changes

EM-21017 - Comerica temporarily waives the signature requirement under the consent-based process during the COVID-19 Pandemic - 03/04/2021