|Received:||7/31/2007 11:26:01 AM|
|Organization:||Missoula Federal Credit Union|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Rentals - whether apartments, storage units, cars, etc ... often require SSN. I'm sure it is both for credit bureau searches and for collection info if need be. Maybe these - and other uses - could be eliminated with a service financial institutions could offer: letter of reference - with specific criteria: Length of relationship, credit score, verification of Direct deposit, etc. Then - if needed - with proper contract presentment - the vendor could obtain information if there is default - or use the FI's collection service. Since FI's would (maybe) charge their members/customers a fee for the LoR - vendors should be required to limit their application fee (some are getting excessive now) and could pass on the collection fee plus a set penalty fee depending on dollar amt & length of collection (or if rental - end of contract or re-lease). We have had attempted home banking fraud by criminals having account numbers and at least the last 4 digits of SS# - before additional log-in security - it could have caused big losses for us when a lot of members used those as their sign-ons and when it was the initial sign-on.