CUNA Regulatory Comment Call


August 2, 2007

FTC REQUESTS COMMENTS ON THE USE OF SOCIAL SECURITY NUMBERS

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6032, if you would like more information about the request for comments or you may obtain additional information here.

BRIEF DESCRIPTION OF THE REQUEST FOR COMMENTS

The FTC is requesting comments on the use of SSNs in the private sector in order to reduce the incidence of identity theft. An analysis of the need to collect and use SSNs by the private sector was one of the recommendations outlined in the strategic plan to address identity theft, which was recently issued by the Task Force.

Here are the specific questions for which the FTC has requested comments:

Current Private Sector Collection and Uses of the SSN

The Role of the SSN as an Authenticator

The SSN as an Internal Identifier

The Role of the SSN in Fraud Prevention

The Role of the SSN in Identity Theft

Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com