| Comment Number: | 531096-00132 |
| Received: | 8/27/2007 8:57:10 AM |
| Organization: | Private |
| Commenter: | Gary Mc Daniel |
| State: | FL |
| Agency: | Federal Trade Commission |
| Rule: | Private Sector Use of SSNs |
| No Attachments |
Comments:
I pray the leaders will permit licensed professionals who our bonded and insured to be exempt from any legislation that restricts access to identfiers used in the course of licensed activity. As a thirty one year veteran of the industry and court certified expert I assure our leaders these idenitfiers are necesary to combat fraud, locate mssing persons, affirm idenities of those with similar surnames, develope back ground information as to the veracity of witnesses and gather relevant conduct information good bad or indifferrnt in official proceedings. to eliminate identifier access will remove far to many checks and balances that reduce the rate of fraud, litigation cost and deception in this great country. As for alternative remedies, it is simpler for leadership to place the burden on financial institution that benefit from far to many fraud related tax deuctions after failing to police themselves in protecting against fraud. If commercial users assigned pin numebrs, passwords and asked for identification as a privieldge of service then freaud would be reduced as much as 80% on credit card realted fraud. When insittutiosn such as AMERICAN EXPRESS demand the "last four soical numbers" during inquiries with consumers and list "pin NUmebrs" on the cards as all others there is on security and informed consumered are vicitmized by their internatl policy, evn if they chose alternative methods. As for offcial document fraud. These bad acts are generated by skilled criminals and none of the immediate measures will make a differnce. As a victim of identity fraud whcih exceeded 60,000 dolars on two separte occassions. I am aware the commercial entity violated due deligence requirements which resulted in the fraud and suspect at years end the tax deduction was to its advantage. From what I see their is an incentive for these institutions to make changes adn police their own negative consquences. We need to penalize institutions not reward them with oimmedaite write offs unless they prove they ahve exercised due deligence to minmize the crime and recover the loss. In one expereince I received a 1099 from the credit card company after litigation proved I was a vicitm adn that teh card comapny woithout authority issued an associate card to a unauthorized person and on 4 occasions. It was then I realized the benfit to the insitution and that they took to no effort to curtail this type of fraud. Changes most be made, but to eliminat access to licensed professionals will cause greater financial losses and increase investigative expenditures to locate or detect the required/responsible party and ligitimate or anticipated litgation. Forget not theat the consumer cna sue a licensed professional or ahve them decertified if they are wronged. Test your selfs, consider how many common names exist and then consider looking for just one without the tools presently available and calculate the cost to the entity that requires the information for legitimate reasons. Second test try to locate a parent or determine who si using a childs social without these tools. As far as you can imagine professional investigators are needed and in fact becoem teh eyes, ears and do bring a solution to the problem, when enforcment fails. I remain available for constructive conversation or testimony as a licnesed professional conducting business as a private investigator for thirty one years and activist for prevention. Regards, Gary J. McDaniel