Changes in CMRA Regulations - Frequently Asked Questions

Highlights

• Flexible offices must apply for CMRA status, using USPS Form 1583-A. Additionally, they will need to upload all data for new and existing customers in the Customer Registration Database (CRD). Centers ensure that their client's documentation (such as IDs) is up to date. 
• Alliance Virtual Offices is developing Verified. This is a portal that allows centers to maintain full compliance with the USPS, which includes managing notarization (if needed), ID expiration dates, and uploads to the CRD. Verified is projected to be completed by Q4 2024. This date may be subject to change based on the USPS schedule of CRD availability. 
  
  

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Background: What are the rules surrounding CMRA compliance?  

Every flexible office center that handles mail on behalf of others must apply for CMRA status, using USPS Form 1583-A (Application to Act as a Commercial Mail Receiving Agency).  

Clients must sign a PS 1583 form, Application for Delivery of Mail Through Agent, giving the center permission to become their CMRA. The form must be signed by a notary or a center representative as a witness. 

The client also provides two types of ID to complete the form (one must have a photograph) before the forms are sent to the Post Office.  

For more information regarding CMRA regulations, you may consult USPS's Domestic Mail Manual, under section 1.8.

What is changing?  

• As of July 1st, 2023, all new clients must use a new PS 1583 form, Application for Delivery of Mail Through Agent (updated April 2023). Any time a piece of information on the form changes (such as expired ID), both for existing and new clients, a new Form 1583 must be submitted. Get the updated PS Form 1583 here. 
• A PMB (Private Mail Box) Number must be provided to every client upon signature and notarization of the PS 1583 document. 
• The center’s PS Form 1583-A, Application to Act as a Commercial Mail Receiving Agency, has also been updated (changed January 2023). Get the updated PS Form 1583-A here. 
• Centers are responsible for ensuring their own and their clients’ documentation and IDs that were submitted with the CMRA form are kept up to date. Any time a piece of information on a form changes (such as expired ID), a new Form 1583-A for the center or Form 1583 for the client must be submitted. 
• Centers must use the CMRA Customer Registration Database (CRD) – scheduled for launch in mid 2023 – to upload all CMRA data both for new and existing clients. A pilot program is in place to test the CRD. There are currently no further updates on the full launch date. 
• Centers will receive notification from the USPS when they can begin accessing the CRD for CMRA documentation. Centers have 9 months from the publication of the CRD to update all client documentation to the new PS 1583 Form, and upload to the database. 
• CMRAs will maintain an online account with the USPS Business Customer Gateway (BCG) portal to access this database. 
• CMRAs and their clients will be required to keep current forms of identification on file with the USPS through the new database. 
• Non-compliant CMRAs may face suspension but will have 30 days to rectify issues and comply with regulations. 

What Alliance Virtual Offices will do: 

• Automatically assign PMB numbers to new clients based on a bank of PMB numbers provided by centers. A representative from Alliance will work with you to establish a bank of unique suite numbers exclusively for Alliance clients.  
• Alliance Virtual Offices is developing Verified. This is a portal that allows centers to maintain full compliance with the USPS, which includes managing notarization (if needed), ID expiration dates, and uploads to the CRD. Verified is projected to be completed by Q4 2024. This date may be subject to change based on USPS schedule of CRD availability. 
• Once the CRD is published by the US Postal Service, Alliance will utilize Verified to obtain new notarized PS 1583 forms from all clients, as well as updated IDs. 
• Alliance will keep track of expiring IDs and follow up with clients to obtain new identification documents. 

When are these changes taking place? 

• As of July 1st, 2023, all new clients must be onboarded with the new PS 1583 form.  
• There is no official data on the rollout for the new online database, the CMRA Customer Registration Database (CRD).  A pilot program is currently in place. The CRD's API will be made available in June 2024, according to USPS's latest update. 
• Once the CRD is published, CMRA compliant centers will be notified by the Postal Service directly. Following the notification, you will have a period of approximately 9 months to collect and enter the new PS 1583 forms into the CRD.  

Do I need to be CMRA compliant? 

Yes. Centers will be required to update their existing PS Form 1583-A to continue receiving mail for their clients. Get the updated PS Form 1583-A here.  

Do I need to provide a PMB Number to every client?  

Yes. The client's PS 1583 form will require a PMB number to be filled out in section 2b.  

How can I provide PMB Numbers to Alliance?  

• Provide a range of at least 50 to 100 PMB numbers exclusively assigned to Alliance. 
• Simply send an email to centers@alliancevirtualoffices.com. Alliance will keep track of the PMB numbers and request more if we run out.  

What if I’ve never used PMB numbers in the past? 

Going forward, you must start adding and tracking PMB numbers for each client. This is a specific requirement in the new USPS updates. 

Should PMB numbers be listed on each piece of mail a client receives? 

According to USPS regulations, every letter must contain the client's assigned PMB. When it doesn't, it must be returned to sender. The post office has full authority to return mail when a PMB number is not present though some postmasters will not return the mail immediately and instead rely on business centers to identify mail without a PMB number.

What is the correct use of a PMB number in an address? 

A PMB number must be shown on the address after the suite number preceded by "#" or "PMB. When no suite number is present for the address, simply include the PMB number after the street address. For example:

Can a PMB number be shared by multiple companies?

Yes, if the same party owns the PMB. For example, a client with multiple DBAs may share the same PMB, but each DBA will require its own PS1583 document. If multiple people will receive mail for the same company, a PS1583 document must be submitted by each mail recipient. 

Other relevant notes around the changes to the PS1583 process:

• A new PS1583 form must be submitted when new IDs are provided. 
• A new PS1583 form must be submitted when the applicant's mail forwarding address changes.
• AN ID number is not required in the PS1583 form when and ID number does not exist, which is the case for some voter ID cards, University IDs, mortgage or lease documents. 

What should I do with mail after the client has been terminated?

USPS regulations (DMM 1.8.4 Addressee and CMRA Agreement) state that you must not refuse mail and continue holding and forwarding for 6 months after the client's service has ended. An exception can be made to this rule if there is a service agreement stating what will happen with mail after the client's service has ended (which may include disposing of it or forwarding it), as long as the agreement does not state that mail will be returned to the post office after termination.  After the 6 month period has ended, mail may be returned to the post office. 

Who is responsible for uploading the new PS 1583 forms and IDs to the CRD, and collecting updated IDs? 

The CMRA – your center – is ultimately responsible. But Alliance is heavily involved in the process, in order to streamline operations, deliver value to our center partners, and serve our clients in the best way possible. 

What is Verified by Alliance Virtual Offices? 

• Verified is a new web-based system, due to be launched in Q4 2024, that will keep track of all PS 1583 documentation and IDs for Alliance clients, as well as your own clients, allowing you to maintain full compliance with the USPS. 
• Instead of receiving our usual “New Client for your Location” email with all the documents attached, you will receive an email asking you to log into your Verified profile, download the PS 1583 form and IDs, and “Accept” the client. 
• Verified will keep track of ID expiration dates and streamline the processes around obtaining updated IDs. Video guides and instructions will be provided to our partner centers as soon as the app is available.  

Do I need to obtain new PS 1583 forms and IDs now for all old/active clients, including our mutual clients with Alliance? 

• No. We recommend waiting until you receive official notification from the USPS that the CRD is ready. Some postmasters may begin requesting updated forms for old clients right away, but the Federal Register has stated that you have 9 months from the date the CRD is published to update all existing documents.  

• • If you begin collecting updated documents now for old clients, there is the possibility that some ID documents nearing expiry will become out of date by the time the CRD is published.  

• Only new clients after July 1st, 2023, are required to have the new version of the PS 1583 form.  
• Edit April 2024
  • The CMRA CRD has been open for the whole country since January 2024, and every currently registered CMRA has received up to five (5) mailed notices to access it and begin uploading their data.
  • Newly registered CMRAs will not be receiving the same latitude as existing CMRAs to become complaint.  The Federal Register Notice was clear this was coming and centers should act immediately to ensure they are properly registered and begin uploading their 1583 data.
  •  Many virtual offices believe they do not need to complete this process for clients that come into the office to work.  That is not the case.  Every client of the virtual office, whether in person or simply mail, must complete a 1583 and the center must upload that information into the CRD.
  • The US Postal Service has sent non-compliance notices to previously registered CMRAs that have not begun to use the CMRA CRD and we are monitoring the uptake on a daily basis. 

When will Alliance collect new PS 1583 documents for old/active clients?  

• Alliance will begin collecting new documentation from existing clients as soon as the CRD is published, and our Verified system is live.