|Received:||8/31/2007 11:35:02 AM|
|Organization:||Triad Investigations Agency|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:Dear Sir: This letter is written in response to recent legislation that would restrict PI’s to the legitimate use of social security numbers. Access to social security numbers is vital in investigations pertaining to locating people such as debtors who have defaulted on loans, witnesses, loved ones, victims of identity theft, child support evaders, professional conmen / scam artists / fraud perpetrators, and criminals. Though the proposed legislation has good intentions it will have dire consequences on the economy if passed. The legislation now drafted is written with the assumption that all people are good hardworking citizens that will abide by the same rules of society and does not take into account those criminal elements that will greatly benefit if PIs lose the ability to access social security number information and consumers are notified of access (criminals, debtors, and con artists who are intentionally concealing themselves would move immediately upon being notified). In addition the legislation will breach investigator-client or attorney-client privileges as it will require an information broker / PI to divulge what information they have developed about the consumer in reference to any civil litigation or criminal cases they may currently be involved in! The access to social security number information and use in our reports to clients has a beneficial use and need in society. It is important that a free flow of information be available to support commerce and our judicial system. It also allows the public, who does not have the resources to manage all of the problems they are faced with, to defend itself without looking to government for help. I am routinely contacted by individuals and businesses who have been let down by government agencies in regard to locating debtors who provided false information on their loan applications, child support evaders, and criminals engaged in both white and blue collar activities such as theft (via the Internet and otherwise), forgery, embezzlement, and other types of financial fraud. As a PI, I use the social security number as a primary means of identification and it is vital that I have access to the full social security number as many of the types of financial fraud scams operated in this country are done so by immigrants who obtained their social security number in line at the Social Security Administration Office with other family members, ergo their social security numbers are very similar with only the last four numbers being different. Many of the family members also have similar names further making it difficult to distinguish which family member is which. Imagine trying to find a Steve Jones or John Smith in the state of California or New York City with no identification! I currently investigate these types of activities for numerous third-party Small Business Administration administrators who loan millions of dollars to applicants daily. Many of these loans were applied for with no intention of repaying them and the funds are diverted to other bank accounts held in the names of other corporate business entities and then re-directed to overseas bank accounts. You can verify this by contacting any office of the U.S. Small Business Administration, IRS Criminal Investigation Division (CID), or U.S. Secret Service who routinely assists in these types of investigations and are overburdened by the enormous volume of cases of this type. A large percentage (majority) of PI’s are ex-law enforcement officers or former FBI, CIA, or IRS employees who have received extensive training and are aware of legal issues and the consequences that follow for distributing sensitive intelligence or information to parties without a legitimate business interest. I am required to be licensed and take C.E. courses and ethics training every 2 years. Myself and other PIs that I know no longer provide SSNs to our clients with the exception of government agencies or their agents.