Another provision of FACTA, Section 115, allows consumers to request that the credit bureau not disclose their complete social security number. Consumers may request that the reporter suppress the first five digits of their SSN. Many creditors use the credit reports to validate the identity of the applicant, including address and SSN reported by the credit bureau. This technique will become unreliable as consumers request SSN truncation. Take a look at your CIP procedures and make sure that you aren't relying on the credit reports to validate SSNs.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 14, 1/04
First published on 01/01/2004