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#26249 - 08/01/02 01:37 AM Confidentiality of SSN
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
We are an ITI bank. In order to comply with the Confidentiality of SSN requirements (I believe it is CA Civil Code Section 1798 - I don't have it in front of me) we have chosen to eliminate an identification field on incoming ACH entries. We have discovered that the elimination of this field has affected our merchant bankcard customers. The indentification field also held information that our merchants used to identify transactions for different business locations and it no longer appears on bank statements.

I am interested to know what other ITI banks have done to resolve this problem. Our merchant bankcard customers can obtain this information from Nova's website, however the process is time consuming and inconvenient.

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Dolly Nugent
CRCM
Opinions expressed are my own.

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#26250 - 08/03/02 09:42 PM Re: Confidentiality of SSN
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Dolly - sorry I didn't get back to you sooner. The whole thing has turned out to be a mess for us as well. Delete the field that contains the SSN and you delete information that is also necessary for Reg E.

I was told by our Ops staff that FiServe reports that portion of the bill will either be repealed or suspended to allow additional time for NACHA to require the originators to no longer place the entire SSN in the addenda fields (or something to that affect anyways.)

In the meantime, I suggest we look up the names and office address and phone number of the legislators that originated this bill and voted for it. Pass it along to our customers and tell them that these folks are responsible for passing laws that required this mess.

Al - can you give us the link to that info?
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CRCM,CAMS
Regulations are a poor substitute for ethics.
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#26251 - 08/05/02 03:16 PM Re: Confidentiality of SSN
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
You can get the legislative history on SB 168 through:

http://www.leginfo.ca.gov/bilinfo.html[/url]

There you can find that Senator Bowen introduced the bill and that the principal co-author was Assembly Member Alquist. Senators Kuehl, Romero and Soto, as well as Assembly Members Aroner, Keeley, Koretz and Longville were listed as co-authors. The Senators and Assembly Members (including your own representatives) can be reached through:

http://www.leginfo.ca.gov/yourleg.html

Glad to be of service.
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#26252 - 08/15/02 11:22 PM Re: Confidentiality of SSN
SJB Offline
Diamond Poster
SJB
Joined: Jun 2002
Posts: 1,210
California
I have been out for a while and just saw this thread.

I guess I don't fully understand the problem SB-168 creates.

You aren't publicly posting the SSAN.
You aren't printing the SSAN on an access card.
You are not requiring the individual to transmit the SSAN and I assume ACH comes in on a secure Internet connection.
You did not mention customer use of a web site, so, I guess the problem is in mailing something (notice of the ACH debit or credit) to the customer with their SSAN on it?

What am I missing?



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#26253 - 08/16/02 12:13 AM Re: Confidentiality of SSN
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
The problem stems from the fact that the Treasury Dept. sends the SSN of the recipient as part of the information on the ACH addenda file (please excuse me if I don't have the terminology exact, I'm trying to summarize this.) Automated systems pick up the addenda file and print all the information contained in it on the statement.

Normally, that's a good thing because it contains useful information such as the time and location of certain transactions or other useful information to identify an ACH entry on the statment.

However, SB-168 says we CANNOT have the Social Security number appearing on the statement that we mail to our customers. Currently, the only way to make sure the SSN doesn't get automatically listed on the statement is to block that particular addenda file which means that all the other useful information gets blocked as well.

Law of unintended consequences - the blocking of the other information now puts us square in the path of a Reg E violation as well as the other problems that Dolly brings up.

So basically, since the Treasury Department is so careless in how they disseminate social security numbers, we are on the losing end of either a federal regulation or a state law. In either case, one set of customers will not be happy.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#26254 - 09/20/02 08:04 PM Re: Confidentiality of SSN
Tina A Sweet Offline
Diamond Poster
Tina A Sweet
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
Thanks for the site Al.
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mailto:tsweet@goldcountrynb.com

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#26255 - 09/21/02 03:16 PM Re: Confidentiality of SSN
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
What's the latest news on this issue? Are we getting an extension for compliance? I'm sure it will be a topic of conversation at the California Bankers Compliance Conference.
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Dolly Nugent
CRCM
Opinions expressed are my own.

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#26256 - 09/25/02 06:14 PM Re: Confidentiality of SSN
Anonymous
Unregistered

The emergency measure to allow the social security numbers on ACH items has been enrolled and is awaiting the Governor's signature. It's AB 1068 if you want to review the bill. I heard that the bill won't be vetoed but will be signed sometime before 10/16/02.

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