|Received:||9/18/2006 8:47:29 AM|
|Organization:||Iowa Student Loan|
|Agency:||Federal Trade Commission|
|Rule:||Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act of 2003|
Comments:Iowa Student Loan (ISL) is a secondary market for the Federal Family Education Loan Program (FFELP), a servicer for FFELP participants and an originator and servicer of private education loans. These comments focus on the proposed rules as it affects the FFELP and private loan programs and the identification of its customers and identity theft. ISL recognizes the need to know who our customers are and recognizes that identity theft is a serious problem. The majority of ISL customers are college students and they are a very transient population. We applaud the Interagencies for allowing us to use the policies and procedure for identity verification that we have developed to comply with the Customer Identification Program (CIP) rules. As a servicer for FFELP participants, who are banking institutions governed by the Regulatory Agencies, under the proposed rules we would be required to make sure our compliance remains within the guidelines of those Agencies as well as complying with any rules that the Federal Trade Commission would write that might differ, even so slightly. This could become a very daunting process, in both the original compliance and any changes that would be made along the way.