|Received:||8/28/2007 1:33:42 AM|
|Organization:||SEATTLE INSURANCE AND LEGAL INVESTIGATIONS|
|Commenter:||JAMES CRONIN, CFE|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:There are many reasons why members of the public and companies need access to records linked to SSN's. The current Graham Leach Bliley Act and Drivers Privacy and Protection Act permissible purposes are well-written and provide coverage as written. To ensure compliance and to protect the public, I would recommend that any entity/individual requiring access to these records be required to provide proof of professional liability insurance in the amount of $1 million dollars per occurance and $2 million aggregate. This is the amount of insurance currently carried by existing legitimate investigators and corporations.