CMRA Changes: Everything you need to know now!
+ answers to your questions
Given that over 300 flex spaces registered for the recent GWA webinar on CMRA regulation changes with Clayton Gerber from the USPS Inspection Service, it’s clear that operators are now tuning in to what’s ahead.
This post will provide clarity on the most significant changes and exactly what a flex space operator needs to do now or in the months ahead.
iPostal1 has had ongoing contact with the USPS for the past 18 months as the new regulations were formulated, providing feedback and recommendations. Now that the dust has settled and there is enough clarity around the regulations and implementation process, we can provide reliable information to guide you. That said, changes continue to be made, so stay tuned for future updates.
CMRA background
The USPS created the CMRA (Commercial Mail Receiving Agency) over 100 years ago, with the last update to the regulations in 2001. The concept is simple: the post office delivers mail only to the addressee, unless the addressee has officially appointed a CMRA to receive mail on their behalf via Form 1583. The CMRA files a Form 1583A with the local post office to register as a CMRA.
There have been two major problems with the existing regulations:
It is an entirely paper-based system, leading to inefficiency and privacy risk.
Many local postmasters are uninformed regarding CMRA procedures, leading to lax compliance and opportunities for bad actors to commit mail crime.
The new system is digital-based and tightens up the recipient verification process by requiring more information on the Form 1583. It also provides greater privacy protection by storing customer information on their Business Customer Gateway portal (BCG), with a new feature, the CMRA customer registration database.
The biggest CMRA regulation changes impacting flex space operators
The customer Form 1583 and the CMRA Form 1583A have both been revised. Primary IDs with expiration dates must be updated upon expiration. The new form went into effect on July 10 for new customers. Existing customers prior to July 10 must submit an updated Form 1583. Spouses will require their own Form 1583 with IDs. A mail recipient with multiple business names does not need to file a Form 1583 for each business entity.
Customer information will no longer be submitted by paper to the local post office, but rather entered into the website portal. Information must be entered manually for each customer. However, iWorkSpaceMail with iPostal1 is providing automated support.
All flex office locations receiving mail will now be required to register as a CMRA if they receive single point mail delivery for their clients, e.g. the mail carrier drops all the mail for all clients in one bundle, to be sorted and distributed by the flex space staff.
The CMRA owner or manager, whoever’s name is on the Form 1583A, will also have to file a Form 1583, just like a customer.
All mail recipients at a flex space location will be required to submit the customer Form 1583. The prior exemption for office tenants or 16 hours of office use has been eliminated.
CMRA’s are expected to enter information for new customers into the CMRA database within 90 days and to enter information for all prior existing active customers within 9 months, once the CMRA account is activated in the customer database with a verification code. Note: Clayton has said as long as they see significant activity on the database, they will work with CMRA locations that need more than 9 months to complete the upload of prior customer information.
There are a number of other changes to information requirements and processes, which we will address in the near future.
Current status of implementing the new regulations
During the summer of 2023, the USPS conducted a pilot program with ten CMRA locations, five of which are iPostal1 mail centers, so we got an early look inside this process. The USPS worked to fix software glitches and modify some rules based on the pilot experience.
In September, the USPS launched the new regulations for all CMRA locations in California, Texas and Wisconsin. We have learned that locations in Delaware, Ohio, New Mexico, Connecticut and Alaska have launched in October. It is likely that many states will not launch until sometime in 2024. A state is launched when the USPS sends a postcard notification to registered CMRAs.
Signup is a 2-step process. The USPS first sends a notification postcard with information to create an account by logging into the USPS Business Customer Gateway. After the account is created, the USPS sends a second letter with a verification code to gain access to the CMRA database where the customer information is entered and stored. The verification code now expires after 25 days, an increase from 14 days, since it has often taken 10 days to deliver. If the code expires, a CMRA can request another verification code mailing by logging back into their account.
What you need to do now
Regardless of your state, use the new Form 1583 for your new customers.
Click Here to download an editable version of the form. Upon completion, scan and save the Form 1583 and each ID separately. Color is recommended for best results. Be sure to clearly name each saved scan so customer information can be easily and correctly retrieved when needed to upload to the CMRA database.
Confirm that your location is registered in the CMRA database.
Registration status. Just because you submitted a Form 1583A to your local post office that was signed by the postmaster does not mean that your location is actually registered, as many postmasters fail to properly upload CMRA information. In fact, Clayton estimates that 30% to 50% of the Form 1583A forms submitted were not registered. The USPS has committed to informing local postmasters about their CMRA duties. But it is your responsibility as the CMRA to take steps to confirm registration, as otherwise there is no way for the USPS to send you the first mailing when your state launches.
Early launch states. If you are in CA, TX, WI, DE, OH, NM, CT, AK and received a postcard from the USPS regarding the new CMRA rules and implementation, you are registered. If not, you probably aren’t.
All states. To confirm registration, Click Here to download a PDF with step-by-step instructions for creating your account in the BCG and viewing the list of registered CMRA locations in your zip code. If you find yours, congratulations, you are registered.
If you don’t find your address, submit a new 1583A to your local post office, get a copy of the signed form and the name of the person you dealt with. If you don’t find your address in the database after 5 – 7 days, send an email to cmraprogram@usps.gov with your form and post office contact name. The USPS will follow up.
If you are registered, you don’t need to submit a new Form 1583A unless your account information has changed. Note: the public USPS.com zip code lookup is not reliable for identifying a CMRA registered location.
How to gain access to the customer database and when to begin using it.
When you see your address in the BCG portal, per the information above, your location is registered. But to get access to your account in the CMRA customer registration database, there is another step.
Early launch states. Once registered, click the Request Admin button next to your address, which will trigger the mailing with the verification code. After entering the code and gaining access to the customer database, you should enter information and upload the Form 1583 and IDs within 90 days for new customers, and within 9 months for prior existing active customers.
For all other states. Since your state has not launched, there is no need to do anything other than begin collecting the updated Form 1583 and IDs from new customers. Since the 9-month window to enter information for all your existing customers begins when you enter the verification code from the second mailing, you may be better off not requesting or entering the verification code until your state launches, likely sometime in 2024, after the busy holiday season.
For iWorkSpaceMail with iPostal1 partners – automated support. iPostal1 partners in any state should not contact iPostal1 customers to request an updated Form 1583 or IDs, nor upload or enter iPostal1 customer information to the CMRA database, as iPostal1 will be doing this work, saving you the time and hassle.
iPostal1 will upload the Form 1583 with IDs and enter information into the database for new customers since July 10.
iPostal1 will collect new Forms 1583 and IDs as necessary for active existing customers prior to July 10, and upload and enter information into the database.
Flex space partners using iWorkSpaceMail for their own clients will also benefit from automated support.
More information on these automated support services will be coming soon.
As we move into the new CMRA environment of more rigorous compliance monitoring, it’s a good time to take a step back to evaluate your mail program strategy going forward and align with a digital mailbox provider that can deliver maximum efficiency and profitability.
FAQs
It’s no surprise that everybody has questions.
Click Here to see the answers to your questions, including many that were asked in the GWA webinar chat on October 25, but could not be answered due to time constraints.
If you have questions about the CMRA regulations, please contact William Edmundson, william.edmundson@uszoom.com, or click here to enter your contact information in the form provided.
Follow iWorkSpaceMail
