|Received:||8/28/2007 6:33:08 PM|
|Organization:||Trusmark National Bank|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Current Collection and Uses of the SSN Financial institutions collect SSNs for Trust, Human Resource, Insurance Benefits, Payroll, IRS, W-2, year-end reporting, deposit accounts (CIP), required government reporting, applicants, and credit checks. The life cycle varies depending upon the application and retention requirement. Government mandates definitely drive the private sector's use of the SSN. Alternatives are available in certain situations, i.e. employee number rather than SSN. It seems that a personl PIN derived from an algorythm might be an alternative. When it comes to identifying customers, the SSN is currently the only identifier used across all lines of businesses. ROLE OF SSN AS AUTHENTICATOR All current applications (HR, Loans, Deposits, Trust, etc.) use the SSN as an authenticator. Until government moves away from the SSN as an Authenticator, financial institutions must continue to use the SSN. THE SSN AS AN INTERNAL IDENTIFIER The cost to move away from the SSN as an internal identifier would involve technology, training, and manpower costs. The barriers preventing financial institutions from moving away from using the SSN involve, federal and state regulations,technology challenges, and credit bureau reporting. ROLE OF SSN IN FRAUD PREVENTION In current fraud prevention, the social security is a key indentifier. It is required for verifications of loan and deposit accounts. Because of existing requirements, no alternatives to the SSN is available for efforts in fraud prevention.. If the use of the SSN was restricted, the ramifications for fraud prevention would be increased difficulty unless alternatives are provided. A restricted use of the SSN would make fraud prevention become more difficult since it is currently used as an important tool. THE ROLS OF SSN IN IDENTITY THEFT Thieves obtain SSNs by theft, hacking, phishing, camera phones. Thieves definitely exploit internal printed documents, crimes committed by "insiders", unofficial access to certain departments, etc. Once theives obtain SSNs they use them to commit identity theft by obtaining new credit accounts, medical benefits, opening deposit accounts, retrieval birth certificates, and updating credit bureau information. Where alternatives to the SSN are available, we feel that no additional risks are presented.