| Comment Number: | 531096-00218 |
| Received: | 8/31/2007 9:50:24 AM |
| Organization: | E. Thomas Sisk Investigations |
| Commenter: | Eamon Sisk |
| State: | NC |
| Agency: | Federal Trade Commission |
| Rule: | Private Sector Use of SSNs |
| No Attachments |
Comments:
As a former police detective who worked on a number of financial identity theft investigations, I can certainly understand the desire to act effectively in the fight against such crimes. I would caution, however, against throwing the baby out with the bathwater. Private investigators, nationwide, legitimately use SSN's to confirm the identities of people being sought for child abandonment, fraud, support violations and the like. The full numbers are also vital in the effort to verify that the person we are looking at is, in point of fact, the correct person - there are many, many "David Williams" and "Frank Browns" out there and it's important that we avoid wasting resources and our client's money following the wrong paths. We use SSN's while investigating insurance fraud - a crime that is nearly as rampant as identity theft, and one that costs the insurance industry (and the citizens who are the stockholders) billions of dollars each and every year. Victims of financial identity theft also use private investigators in their battle to regain their lost financial credibility - ironically, removing access to SSN's would inevitably hurt some of the very people you are trying to protect, by placing additional hurdles in front of the folks who are trying to assist those very victims! Please add my name to those raised against the specter of any law restricting the use and access of SSN's to private investigators. We are one of the most regulated industries, undergoing background and criminal history checks for character and honesty prior to licensing. We have a legitimate need for the information and have shown we can be trusted with it. Thank you. Tom Sisk E. Thomas Sisk Investigations