|Received:||9/5/2007 8:51:26 PM|
|Organization:||Edward R. LeFevour and Associates Ltd.|
|Agency:||Federal Trade Commission|
|Rule:||Private Sector Use of SSNs|
Comments:As a licensed private investigator for over 14 years as well as a former law enforcement officer, I consider myself to be well versed in the need to obtain social secuirty information related to investigations by licensed private investigators. My clients include government agencies, major insurance companies, law firms, banks, as publicly traded businesses. All of the aforetomentioned have required investigations related to FCRA guideinesfor purposes of litigation discovery, corporate due diligence, background investigations and other related matters. The social security number in its entirety is essential for these activities and those that major business clients and the legal profession expect. Private investigators are prohibited by law from utilizing law enforcement databases. However, our clients need a means to verify a person's identity and link that identity to other critical aspects of an investigation. This is especially important when investigating fraud or conducting background investigations in order to prevent fraud. Most states (including the two I am licensed in i.e., Illinois and Wisconsin) have strict requirements related to becoming a licensed private investigator. Part of the licensing requirement involves an FBI criminal background check as well as a State Police Criminal Background check. As stated, when obtained by a licensed and reputable licensed private investigator, the social security number provides the critical link for an acurate and timely investigation. Again, my corporate clients expect that I will be able to perform these duties for them. The use of social security numbers for purposes of investigation is also critical in order to verify citizenship and identify any irregularities even those that might suggest a link to organized criminal activity. As an ASIS Certified Protection Professional, I am also certified by the Department of Homeland Security under the Safety Act, which prevents liability protection for acts of terrorism. Thorough investigations and identification verification have never been more important. I would hope that you carefully consider any legislation which might prohibit reputable private investigators from obtaining, through legitimate means, a social security number for purposes of investigation. Should such access be prohibited by the Federal Government, I will be in a position to have to notify my corporate clients of such prohibitions and recommend engaging lobbying efforts in the nation's capital in order to make lawmakers aware of the consequences to the business community of such prohibitions. Again, private investigators provide critical servies to the nation's private businesses and as such they should not be restricted in the use of social security numbers for purposes of legitimate and legal investigations.