|Received:||3/27/2007 1:56:00 PM|
|Agency:||Federal Trade Commission|
|Rule:||Proof Positive: New Directions for ID Authentication|
Comments:Dear Sirs, The subject of identity theft as we all know has grown by leaps and bounds in the past decade. In my experience, human nature will always accept someone's identity as being "valid" if a driver's license is presented. Very few individuals will go a "step further" to validate a driver's license. Loans, bank accounts, and various other accounts are granted on stolen ID"s. All of these items are provided based on a Driver's License. In most if not all cases, the individuals I have been able to identify are successful because a fake ID was purchased or an employee of the BMV was paid off to provide a fake ID. The motivating factor at all levels of fraud is obviously some sort of monetary gain. The State of Ohio, for example, requires an actual social card (copies not accepted), birth certificate (copies not accepted), bills showing stated residence, and the previous ID (regardless of State of issuance) before a driver's license would be issued. One would think this documentation would be enough. All too often the fraud begins at the social number level. One then must ask "how" a social number and social card can get into the wrong hands. And the answer is two fold and simple: 21st Century human beings don't care about too much other than themselves and the wrong people are in the wrong jobs. Human beings in the 21st Century don't care for a couple of key reasons: They are beyond financial distress and completely self-centered on materialistic and superficial items (tangible) money can buy. Therefore, when any employer, government or private, hire people at minimum wage or bare minimum pay, you will ultimately get what you pay for. Having said that, not all humans are motivated in this manner, sad but true, the majority is motivated by this reality. So, when you have a single mother with several children working 40 hours a week behind a desk that deals with a rude general public, it begets this attitude of apathy. This apathy makes employees more assessable to moral compromise. The compromise comes when one is offered the opportunity to "turn a blind eye" to fraud, and to clearly not pay attention to details because they simply do not care. The wrong people are in the wrong jobs. Where do you find the sharp people? You find them at the college level, working for prisons, bank security, government security, etc., You find those people maybe even highly recruited and you hire them in jobs that matter: Managing the Social Security Administration, Loan/Credit Underwriting, Supervising all BMV locations, etc. Those individuals then recruit and hire only the "best of the best." All of this must, absolutely must, be accompied with an appropriate paycheck. Therefore, one has eliminated the need to compromise. These managers should go back to the days when a credit bureau screen was acceptable and pay close attention to the "life styles" of your candidates. But then of course, we would all have to take on the liberal political organizations that would chant discrimination. (The left wing political activist often forget about what is good for the masses). The left wing political activists could be dealt with later. But you get the point? Pay attention to the people you hire and hold the managers accountable for performance. For example, a department should be created to track the reports of identity theft caused by a fraud driver's licenses and social cards. Drill down into the locations that produce the most fraud items. Then hold the managers and hold all people accountable even if that meant a threat of criminal punishment or imposing fines on individuals responsible for the production of fraud social cards or Driver's Licenses. If these initial key factors are restructured and highly managed, our country would within years see the pendulum swing in a positive direction where this subject is concerned. Before the system would be clean, an audit of all state issued IDs would have to be in place. The only possible way to implement a full scale audit of existing IDs would be to hire a private sector security firm outside of the Social Security Administration to cross reference and double check ALL issued social security numbers to date. This security firm would have to scrutinize for duplicate socials, socials used by multiple names in multiple locations, socials listed as deceased. There would then need to be several categories established: Category for deceased socials with no activity, deceased socials with activity, multiple names using one social, duplicate socials etc., Once those are broken down, the specialized team of individuals hired would drill further down into the problem and weed out the criminals before a crime is committed regardless of how time consuming or difficult this task would be. It must be done. As with any job or department in any company, no one, no one and I mean no one can go about fixing a problem without first understanding how a problem got to the point it did, gut the problems, and getting the right people in to fix them with the best game plan. Period. In conclusion, the problem of identity theft is not exclusive to the Social Security Administration but appears to be a huge part of the root problem. In my experience in chasing fraud suspects, the fraudulent use of a social security number or the fraud issuance of a Social Card/Driver's License seems to be the first step in a criminal's plan to fraud us all. Once the criminal is successful using the 9 digits, there is not much by way of monetary gain available in our capitalistic society that the criminal can not obtain with very little effort on their part. We as the good stewards and productive citizens must make this issue our "cause." Otherwise, we continue to pay for it both literally and figuratively.