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                                    ADMINISTRATIVE REPORT

                                                  Date:  November 12, 1996
                                                  Dept. File No.:  PRA/96-061

          TO:       Vancouver City Council

          FROM:     Chief Constable

          SUBJECT:  Amendment to the License By-law
                    Postal Box Rental Services


          RECOMMENDATION

               A.   THAT the License By-law be amended to require businesses
                    operating a postal box rental service to verify the name and
                    current residential address of every person who rents, leases,
                    owns or has possession of a post box on the premises by means
                    of requiring every person who rents, leases, owns or has
                    possession of a post box on the premises to produce defined
                    identification; and  requiring the businesses operating a post
                    box rental service to record the type of identification used.

               B.   THAT the License By-Law be amended to include businesses
                    operating a mail drop service.  The amendment will include a
                    requirement for the business operating a mail drop service to
                    verify the name and current residential address of every
                    person who for or on behalf of whom that business collects
                    mails by means of requiring every person for or on behalf for
                    whom that business collects mails to produce defined
                    identification; and requiring the businesses operating a mail
                    drop service to record the type of identification used.

               C.   THAT the Director of Legal Services be authorized to bring
                    forward the appropriate amendments.

          CHIEF CONSTABLE'S COMMENTS

               The Chief Constable RECOMMENDS approval of the foregoing.

          COUNCIL POLICY

          There is no applicable Council policy.


          PURPOSE

          This report recommends a change to the License By-law to make the by-law
          more effective in the regulation of the users of post boxes and mail
          drop services.

          BACKGROUND

          In 1982 the License By-law was amended to provide some measure of
          control over post boxes.  The amendment arose out of concern that the
          boxes could be used by unknown persons to fraudulently receive money or
          orders in connection with an unlicensed business.  The amendment
          required the operator of a post box rental service to maintain a record


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          of the people using the service; and that the record be available for
          inspection by the Chief License Inspector and Chief Constable.  It also
          required the licensee to ensure that any person using the service for
          business holds a City business license.  The Vancouver Police Department
          however, has not found the by-law to be an effective deterrent in
          preventing fraudulent use of the postal boxes by the users and have
          initiated a request to amend the by-law.

          DISCUSSION

          The Vancouver Police Department s Commercial Crime Unit spends a great
          deal of time on investigations surrounding persons establishing false
          businesses to take advantage of unsuspecting people.  Criminals use
          legitimate businesses that offer mail services such as, postal box
          rental services or office rental services, to establish an address from
          which they can not be traced. This protects their anonymity from victims
          and the police.  Police investigations are limited by the inaccurate
          information of the user of the postal box or service  which is
          maintained by the operator of the business.  Presently, there is no
          requirement for the person operating the business of a postal box rental
          service or office rental services to verify a person s name and address,
          using specific identification (identification will be defined as in the
          Second-hand Dealers By-law) and to record the type of identification
          used to verify same. 

          A postal box rental service is a business that rents, leases or sells a
          receptacle or box for receiving mail. The user accesses their mail by a
          key.  An office rental service provides various services to businesses
          or individuals such as: reception services, office space, e-mail and
          mail drop services.  For a monthly fee the office rental service,
          provides an address, usually an actual office address as opposed to a
          post box number, to where the mail is delivered.  The staff at that
          location sort the mail for their various customers.  In most cases the
          mail is not placed in a physical box or receptacle, but rather the owner
          of the mail either physically picks it up or it is delivered by courier
          to the user.

          Amending the License By-law will act as a deterrent to fraudulent use of
          post boxes or mail drop service, once possible offenders become aware
          that proper identification is required.  In addition, maintaining
          accurate user information aids the police when investigating an alleged
          fraud where the suspect has used a postal box or service to  scheme or
          scam  unsuspecting citizens. This  also assists the Permits and Licenses
          Department in their regulation efforts. The same person who allegedly
          commits the fraud using the postal box or service  invariably does not
          have a business license.  When Permits and Licenses investigates a
          citizen complaint of this nature, they often find the addresses and
          names maintained by the Postal box or mail service are incomplete or
          false and; therefore, the investigation often ends at the business that
          provides the service.

          The proprietors running these services will benefit as its ensures their
          customers are providing accurate information.  This type of by-law was
          enacted in Burnaby and it includes the same requirements that this
          amendment will have.  Many of the same businesses that offer these
          services have businesses in Burnaby where they are already subjected to
          the by-law.  The majority of persons who access these services are
          legitimately using the service, it is only a small percentage who


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          fraudulently use these services.  That small percentage however,
          disproportionately tax the city s limited resources.  This amendment is
          targeted at reducing that financial cost as well as taking a proactive
          approach to preventing crime.

          ENVIRONMENTAL IMPLICATIONS

          There are no environmental implications.

          SOCIAL IMPLICATIONS

          The by-law amendment will improve investigations and law enforcement of
          fraudulent users, which previously were extremely difficult if not
          impossible to follow-up.  It will also improve the service response by
          the police to the public regarding these types of investigations.

          FINANCIAL IMPLICATIONS

          Permits and Licenses Department and the police have limited resources
          and trying to make efficient use of those resources is a priority by
          both departments.  The amendment does not add any cost to the businesses
          providing the services defined under the by-law or the City. 

          IMPLEMENTATION AND COMMUNICATION PLAN

          The recommended by-law amendment is a consequence of the inability and
          in some case reluctance of businesses to obtain current and correct
          information from the users of the postal boxes and mail services.  Upon
          approval of the by-law amendments written notice will be communicated to
          the businesses affected by the amendments.

          CONCLUSION

          The recommended by-law amendment will prevent crime by acting as a
          deterrent to some offenders, as well as assist the police and Permits
          and Licenses Department in any required follow-up when investigating an
          allegation.


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