SubscriberWise Proposes Child Identity Theft Protection Legislation to U.S. Congressman Bob Gibbs of Ohio as Rep. Maxine Waters Introduces Credit Improvement Act of 2014

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Following contact from Congressman Bob Gibbs’ Office and a two-hour meeting with Congressional Field Representative and District Director Darrell Kick, SubscriberWise president and founder David E. Howe offers to the nation The SubscriberWise Child Identity Protection Act.

We can and must do better for the sake of victim children.

SubscriberWise®, the leading provider of analytics driven subscriber decision management technology and the nation’s first and largest issuing consumer reporting agency for the communications industry, announced today that the company is pleading with Congress to introduce a legislative initiative that would require the Social Security Administration, the U.S. Department of Commerce, the Office of the Inspector General, the National Technical Information Service, and any other responsible federal agency, to create an index of child social security numbers that would be referenced to dramatically reduce child identity theft.

SubscriberWise’s child protection proposal follows a substantial number of child identity thefts that have occurred over the past decade at MCTV, where Howe is also the company credit manager. Nationwide, thousands of children are victimized every year.

SubscriberWise has respectfully requested its representative – Robert Gibbs, U.S. Representative for Ohio's 7th congressional district – to urgently introduce a child protection bill and engage the appropriate committee(s) as soon as possible.

“This ‘child master index’ (similar to the Death Master File, or SSDI) would be available only to specified organizations that have a legal permissible-purpose to access and disseminate any information,” said David Howe, president of SubscriberWise. “The system would essentially freeze child SSN’s and identify to creditors that the number matched belongs to a minor (i.e. ‘File not returned, indicates minor: SSN frozen by federal law.’). From the standpoint of real-time database query and security purposes, no personally identifiable information need be associated with the SSN index to guarantee child protection.

"Federally regulated Equifax, Experian, and TransUnion would be among national organizations approved and required to reference the index,” indicated Howe. “The three national repositories would instantly alert creditors that an SSN submitted with a credit application is blocked and registered to a minor. Credit scoring agencies such as FICO could also assist in creating technology that could trigger a ‘child’ alert during the calculation of a score, similar to the technology that prevents consumer files from being scored because the file contains one or more ‘deceased’ indicators.

“It’s important to understand that the Federal Trade Commission has mandated ‘Red Flag’ compliance on virtually every company in the nation that maintains a billing, credit, or payment record on a consumer,” explained Howe. “Red Flag compliance is important. Its purpose is to mitigate identity theft. It’s a proven and effective regulation especially for call center environments where the majority of service applications are processed over the telephone. Unfortunately, there’s a dangerous gap that exists today as it relates to protecting the identity of minor children. It's common sense that Congress must write a law to close this gap at the same time federal regulations mandate identity theft mitigation and Red Flag compliance on creditors across this nation,” argued Howe.

“If an adult can ‘freeze’ his or her credit file to increase security and limit access, then similar technology should be mandated to protect social security numbers that belong to children,” commented David Hoffer, SubscriberWise vice president and CFO. “Simply stated, it should be near impossible to create a consumer report with an SSN that is submitted with a credit application and, in fact, belongs to a child. Unfortunately, that’s not the reality today. It’s time for legislators to strengthen identity protection for children.”

“Astonishingly, among every SubscriberWise member operator across the nation, only .01 percent of ‘No Hit/No Subject Found’ credit submissions are today indicated as files that may belong to minors,” explained Howe. “It’s long been our position that the federal government should mandate 100 percent child-SSN suppression because the technology to accomplish this without compromising children’s security certainly exists today. And I know unequivocally from numerous and recent conversations with systems professionals and executives at the national repository, they share this expectation profoundly.

“I’ve personally managed more than 600 child identity frauds in my career,” stated Howe. “I’ve been called to testify in a felony identity theft trial involving a child’s stolen identity and I’ve met with numerous police and prosecutors over the years. I’ve exposed several synthetic frauds that have duped creditors around this nation and that involved innocent children. I’ve counseled young adults who’ve learned that their parents had stolen their identity when they were 15 or 16 only to later learn that they had a huge unpaid balance due the cable operator along with collections and ruined credit. It’s been my experience over the past decade that police and prosecutors, including FBI and detective bureaus, they simply don’t have the resources, the training, and the know how to effectively manage this problem - even when the evidence of fraud is overwhelming and undeniable."

“Education about child identity fraud and even the threat of prosecution are proven insufficient to deter this behavior,” continued Howe. “Moreover, it’s not the intent or the desire of creditors to pursue criminal charges against individuals – usually parents or relatives of the victim children – who engage in this illegal behavior. Rather, the goal for creditors is to maintain honest relationships with their customers while avoiding additional liabilities at the same time protecting their investments. Obviously the goal for every creditor is to also protect children from the negative consequence of this behavior.”

“During the past 10 years, I’ve consulted with many professionals and fraud experts about technology to protect child identities. I’ve contacted virtually every federal agency related to social security to discuss this problem and suggest solutions.

"The fact that a national credit repository could (and does) create a fraudulent consumer report with a child’s stolen social security number should motivate the congress to make this issue an extremely urgent priority (http://www.subscriberwise.com/U.S._Creditors_Criminally_Duped.pdf ). It should anger and outrage every parent, every creditor, and every citizen of this nation. I’m hopeful that other concerned citizens, consumer advocacy groups, and businesses, will contact their elected representatives and demand immediate action. It’s time to tell the Congress and the Social Security Administration that addressing this problem more effectively is a must.

"For the record, I’ve also had a number of conversations with executives and professionals at the national repositories concerning this very subject. I’ve not had a single individual disagree about the need to protect a social security number that is issued to a known and confirmed child. I’ve not heard a single justification why a database to block SSNs of living children does not exist today.

"We can and must do better for the sake of victim children.

“Yes, it’s time for Congress to introduce legislation to close this gap,” emphasized Howe. “It’s time to deliver a child protection bill that will protect innocent and helpless victims while also offering creditors the same (http://eon.businesswire.com/news/eon/20130924006571/en/FTC/Parental-Identity-Theft/Child-Identity-Theft ).

"I genuinely thank Congressman Gibbs and District Director Darrel Kick for their advocacy, time, and consideration of this critical proposal.

"I can hardly wait for the President of the United States of America to sign the SubscriberWise Child Identity Protection Act into law.”

The Social Security Administration (SSA) changed the way Social Security Numbers (SSNs) are issued on June 25, 2011. This change is referred to as “randomization.” The SSA developed this new method to help protect the integrity of the SSN. SSN Randomization will also extend the longevity of the nine-digit SSN nationwide. This change also offers an immediate justification to write a policy change that will protect innocent children. (http://www.businesswire.com/news/home/20131120006465/en/SSN-Randomization-Incriminates-Daddie-Dearest-SubscriberWise-Reveals )

About SubscriberWise

SubscriberWise® launched as the first U.S. issuing consumer reporting agency exclusively for the cable industry in 2006. In 2009, SubscriberWise and TransUnion announced a joint marketing agreement for the benefit of America’s independent cable operators. Today SubscriberWise is a risk management preferred-solutions provider for the National Cable Television Cooperative. SubscriberWise technology has prevented thousands of child identity thefts and uncovered the misuse of personally identifiable information for operators everywhere.

SubscriberWise contributions to the communications industry are today quantified in the multiple tens of millions of dollars annually.

SubscriberWise is a U.S.A. federally registered trademark of the SubscriberWise Limited Liability Co.

Contacts
SubscriberWise
David E. Howe, +1 330-880-4848 Ext: 137

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David E. Howe
SubscriberWise
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