|Received:||8/30/2007 9:49:19 AM|
|Organization:||Advocates Investigative Group|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Sirs, with regard to SSN access from those of us in the private sector, specifically licensed, insured and credentialed investigative agencies I would like to share these thoughts. I have been an insurance investigator for over 20 years. I also worked federally with HICF as a Medicare Fraud Investigator. Over the years, I was able to cross reference driver's license issuance in Florida with a SSN check, for insurance clients throughout the US. These searches either legitimized or cast doubt on the identity of claimant's involved in various accident schemes. In those years I probably caught 50 illegal numbers being falsely reported on Insurance Applications. Many of these were illegal immigrants and criminals intent on remaining unknown as to their true identity. All of these people were committing felonies. Over time the access to this information eroded to a point where a agency can barely do a realistic background on any applicant. This has hurt everyone. There is NO Law Enforcement Agency charged with verifying SS numbers for the private sector. A privates business, IE an Insurance Company, does not know if the person purporting to be who he says he is, is really that person. Limiting this access to those of us licensed and bonded hurts private business and the nation at large. How many of the 911 hijackers used similar methods to allude detection? We need this information to determine the legitimacy of people we run across in our daily business. Having worked both for the private sector and the Fed Government, I can easily state that the private sector is much more efficient at stopping fraud, and determining the validity of a person. A negative hit on a SSN, means a mistake has been made or a more ominous effort is underway to hide identity. This effects people in many areas: Child Support Enforcement, legal paying of taxes, SS and Medicare taxes, fleeing felons, illegals, terrorists crooks, scam artists and the like are all "getting through the cracks". This seepage is hurting all of us. It simply is wrong to hide this data from those of us who use it successfully. The real effort should be in cracking down on the "seller's" of this info, the large database companies that sell to anyone. I implore you bureaucrats to understand that we are on the front line of stopping the very thing you are. We can do it faster, better and more frequently with access to SSN's. I could list the tens of thousands, upon millions of dollars I have saved insurance companies through this detection. I could also list a myriad of cases I have verbally alerted to INSS officials. Space here is limited. The common thread? Very few of these fraudulent users of SS numbers were ever prosecuted, but the private sector DID NOT PAY these crooks. The message? We in the private sector do it better, and more efficiently then do those charged with "officially" helping the US Taxpayer. This is not an indictment of the whole system, but it is a plea for you to carefully consider actions in which access to this vital info may be terminated, hurting this country far worse then any of you may realize. There are REAL, tangible incredibly necessary reasons to allow us access to this information. Otherwise the bureaucrats will be in charge of everything. Ask yourself this...what exactly can a bureaucracy do better then a private, insured licensed business. The answer is nothing. If we "mess up", it's our livelihood. Please allow continued access to licensed, insured, and credentialed businesses whose purpose is to stop fraud, not enhance it.