Recently, the USPS® sent reminders to the mailing industry regarding the regulations surrounding the completion of the NCOALink® Processing Acknowledgement Form (PAF). Specifically, USPS® stated that some companies that are acting as Broker-Agents for NCOALink® services are not completing the PAF accurately. “Broker-Agents should not complete PAFs as the List Owner if they are not indeed the owner of mailing lists being processed through NCOALink® services.” This is an important reminder, as it is related to a federal regulation (Privacy Act of 1974).
The USPS® went on to remind that in the Reports section of the NCOALink® Licensee Performance Requirements, it states: “Under no circumstances shall a third party Broker, Agent or List Administrator be considered the Mailing List Owner nor have the authority to sign on behalf of the Mailing List owner.” By signing as the List Owner, a Broker-Agent is knowingly completing the PAF inaccurately.
The PAF Guide, which is located on the USPS RIBBS® website at https://ribbs.usps.gov/ncoalink/documents/tech_guides/PAF_GUIDE.PDF , defines the List Owner as:
• The person or company for which NCOALink® processing will be performed
• The owner of the mail created from the mailing list; the one party in the NCOALink® process that is driving the mail without whom any mailing would occur
• The List Owner is the beneficiary of the NCOALink® processing
The Broker-Agent, as described in the PAF Guide, acts between the List Owner (NCOALink® client) and Licensee and in most cases is a “reseller” for Licensees’ NCOALink® services. Broker-Agents must not retain any files that have been processed through the NCOALink® service longer than 45 days. They may receive updated addresses from the NCOALink® Licensee for the purposes of delivering the updated mailing list to the List Owner, but is never the final repository for the data that was processed through the NCOALink® service.
It is imperative that the NCOALink® PAF is completed accurately. If you are a Broker-Agent, you should never sign the PAF as the List Owner if you do not own the mailing list that is being prepared for NCOALink® processing. Please review the NCOALink® PAF Guide at the above link for guidance on completing the PAF. Additionally, share this document with your customers to educate them on the importance of the PAF, specifically the accurate completion of the form.
If you have questions regarding the NCOALink® PAF, the USPS® asks that you please feel free to contact the Licensing and Certification Department at ncoalink@usps.gov.
