| Comment Number: | 531096-00188 |
| Received: | 8/28/2007 5:29:12 PM |
| Organization: | SAGE INVESTIGATIONS, LLC |
| Commenter: | Edmond Martin |
| State: | TX |
| Agency: | Federal Trade Commission |
| Rule: | Private Sector Use of SSNs |
| No Attachments |
Comments:
My comments on the need for Social Security numbers in my profession are as follows: I am a retired IRS Special Agent and am the owner of Sage Investigations, LLC. My firm is 5 years old. I am licensed with the State of Texas and a member of TALI and NCISS. In my investigative activities involve individuals, attorneys (civil and criminal), and business entities (Corporations, partnerships and sole proprietorships.) The SSN is valuable in investigation in distinguishing one (John Smith from another John Smith). The entire system of data is maintained by most every entity in the country is based on the SSN. Some states use the SSN for their driver's license. Unfortunately or fortunately, we have entered the computer age and access to information is more readily available. This access can be for good purposes and for bad purposes. The good purposes are serving clients who are 1.) entering a divorce and their husband has secreted assets and has not disclosed them to the courts; 2.) the divorcee whose ex-husband is no longer paying child support, yet secreting assets from his former wife and the courts; 3.) the individual who has been defrauded and has secured a judgment from the courts and needs to locate the defendant and his assets so that he can recover the judgment. 4.) The attorney who determines he needs a witness for court the next day to defend his client. 5.) The financial institution that must perform due diligence and a background search before completing a loan. 6.) The corporation that needs to protect itself from mortgage fraud. The list goes on and on. Please do not think of Private Investigators as the stereotypical TV Private Eye. On the contrary, we perform a needed function and access to the SSN is very valuable and is protected within my firm. In today’s world only if the average person can interest a law enforcement officer to investigate a matter will the matter be resolved. As a result, most people cannot get justice. If you are involved in a civil matter, justice is even further away. Most people think of hiring an attorney and suing, but many times a Private Investigator must put the information together for the attorney to consider taking the case. The licensed private investigators serve a purpose in the community to bridge the gap between the police and the emptiness of nothing being done to help a person. We therefore render a service to our clients and the SSN is generally an ingredient in the service. I know that Identity Theft is pushing this desire to eliminate the use of the SSN. Please for the sake of all law abiding Americans do not take access to information to the SSN away from the legitimate investigators. Instead, add more controls, require licensing of those using the number and promote the security and possibly the encryption of information to protect the SSN. Instead of using, a "shot gun approach" at solving the identity theft problem and other crime in which SSNs are used fraudulently, use a "rifle approach" and zero in on the more difficult target the criminal that abuses the SSN. Edmond J. Martin, CFE, TCI Sage Investigations, LLC