The CoMRAA Board Meets in DC

On January 13^th, the CoMRAA Board of Directors met at the Premier Workspace offices in Washington, DC.  

The following officers were elected: 

Chairman, William Edmundson, EVP Workspace Channel, iPostal1 

Secretary, Ann Daly, Vice President Global Postal Relations & Compliance, Quadient 

Treasurer, James Fulgenzi, Head of Public Policy and Strategic Communications, Proof 

All three officers also serve as CoMRAA MTAC (Mailers Technical Advisory Committee) Representatives. 

Additionally, the Board finalized the 2026 Priorities. They are as follows: 

1. Opt-Out Forwarding Removed Address the removal of the opt-out forwarding option from the DMM on 11/3/25 without notice to the CMRA industry, which later appeared in the 1/18/25 quarterly update, and determine the appropriate appeal process for this rewrite. 

2. ID Requirements and Digital Modernization Advocate for immediate changes to DMM language to permit digital modernization, including biometrics, facial recognition, and KYC processes, to reduce fraud and provide alternatives to in-person and online notarization. 

3. Quarterly Reporting Certification Question why quarterly report certification should be blocked when only one Form 1583 includes an expired ID, and propose a process that isolates noncompliant addresses without stopping full certification. 

4. BCG to COP Modernization Participation Participate in the upcoming workgroup modernizing the BCG to the Customer Onboarding Portal (COP) to ensure CMRA requirements and use cases are fully included. 

5. USPS API Awareness and Feedback Clarify how, and improve the process on how CMRAs are informed that a USPS API is available and determine whether USPS is seeking industry feedback on API functionality and implementation. 

6. Form 1583 Box 6 Requirements Review current requirements for new Form 1583s related to Box 6, including: a. Loss of customer history b. Linking the customer to the Form 1583 rather than to the CMRA 

7. Expanded Definition of CMRA Address the expanded definition of CMRA to include Registered Agents and Freight Forwarders, and determine how this change will be communicated and implemented. 

Determine a plan to attract Registered Agents and Freight Forwarders 

8. Centralized / Bulk Form 1583-A Processing Utilize and scale the centralized or bulk Form 1583-A process used by Carl Swanson, which allows companies with multiple locations to have multiple 1583-A forms processed simultaneously by one Postmaster. 

9. Compliance Timeline Clarity (30 vs. 90 Days) Seek clarity and consistency regarding compliance timelines, noting that while current enforcement may be lenient, DMM 508.1.8.3e allows USPS to terminate CMRA authorization for noncompliance within 30 days or less. 

10. Addressing and PMB Requirements Determine whether USPS may stop mail delivery if a single addressee does not include a PMB in the address, and clarify why a PMB designation should still be a requirement. 

11. Formal Escalation and Appeals Process Define whether a formal escalation or appeals process exists when issues arise, including escalation with: a. A Postmaster (PM) b. The BCG 

12. Fraud Prevention Best Practices Develop a Fraud Prevention and Reduction Best Practices document and/or tool for CMRA operators. 

13. Bank Acceptance of CMRA Addresses Address challenges related to banks registering businesses using CMRA addresses, including: a. Variations or differing interpretations of laws by state b. Opportunities to improve universal acceptance of CMRA addresses c. Whether CoMRAA should engage large banks or banking associations to educate them on CMRAs and regulatory updates 

14. USPS OIG Audit – Recommendation #3: Clarify policies and procedures 

Provide feedback on policies and procedures to assist USPS’ efforts before the committed deadline of June 30, 2026. 

15. Devise a process to approximate USPS annual savings that CMRAs provide 

16. Manual Change of Address 

Explore options to ensure that manual COAs are processed correctly and in compliance with CMRA requirements. When a manual COA is processed by USPS processing software, in many cases it autofills the address and bypasses the PMB number causing mail to be noncompliant. 

The next Board meeting is scheduled for late March or early April.