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       IntroductionCredit Score BasicsCredit Scores - AdvancedRe-ScoringObtaining Your Credit ReportReading Your Credit ReportDisputing ErrorsIdentity Theft BasicsMaking & Mixing Credit ReportsReinvestigations (or not)HistoryCredit RepairDebt CollectionAuto InsuranceHomeowners InsuranceMortgage InsuranceThe Color of Credit ScoresSpecial ChallengesOpting OutImpermissable AccessDamage & DamagesThe 2003 FACTA BattleMissing Credit LimitsConclusion |
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Credit Scores and Credit Reports, by Evan HendricksChapter 13 Auto Insurance Every move you make, Every vow you break,
When it comes to credit reports and how they are used, insurance may be the least known and most mysterious area. This is an oddity in a sense because from the beginning, the Fair Credit Reporting Act has declared that "insurance" is a permissible purpose for using credit reports. In this chapter, we will explore the insurance industry's use of traditional credit reports and then examine the rise and spread of a newer kind of report that details consumers' driving records and property claims history.Every smile you fake, Every claim you stake, I'll be watching you — The Police (Rock Group) "Every Breath You Take" In the late 1990s, it became increasingly common for auto insurers to use credit scores in the course of deciding whether to cover drivers and what premium they should be charged. The practice grew increasingly controversial as public knowledge of the practice spread. Many people could not see the connection. Why should you have to pay a higher rate for your car insurance because you had unpaid bills or some other financial problem. Some consumers who had never had an accident or a moving violation were faced with sharply raised premiums when their renewal notices arrived. The controversy quickly spread to state legislatures. As of January 2004, three states — Maryland, Utah, and Washington — banned the practice outright. Twelve states have laws setting restrictions, often allowing insurers to use credit scores, but requiring that the score not be the sole determinant or reason for raising rates or denying coverage.205 Twenty-six states regulate insurers' use of credit scoring by requiring greater notice and reporting.206 Despite the movement to restrict use of credit scores, they are, in fact, used widely, particularly by auto insurers. Stress & Risk-Taking In fact, auto insurers are passionate in their belief the credit scores they use are one of the best predictors of future losses. Allstate Counsel Steven R. Sheffey said, "Credit-based insurance scoring is the most significant advancement in cost-based pricing in at least the past 30 years."207 In the insurance world, you do not have to explain why certain kinds of data predict risk, only that they do, he said. Sheffey said that authoritative research208 showed there are two basic explanations as to why insurers are able to find information in your credit report that is predictive of future losses. 205 Arkansas, Georgia, Hawaii, Idaho, Illinois, Louisiana, Minnesota, Missouri, Montana, Oklahoma, Washington, and Wisconsin. See the Web site of the National Association of Mutual Insurance Commissioners, http://www.namic.org/state/credithistory.asp, for an overview and, http://www.namic.org/state/creditlaws.asp, for a brief description of each State's law. 206 Arizona, California, Colorado, Delaware, Florida, Georgia, Idaho, Kansas, Maine, Maryland, Massachusetts, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New York, Ohio, Oregon, Rhode Island, South Carolina, Texas, Utah, Virginia, Washington, and West Virginia. Some states have more than one kind of insurance-credit scoring law, hence the overlap. (See Footnote 1) 207 Letter from Steven R. Sheffey to Evan Hendricks (undated), received in February 2004. 208 Sheffey said there were over 30 articles or studies supporting the stress and risk taker theories. One of them was "The Use of Credit History for Personal Lines of Insurance; Report to the National Association of Insurance Commissioners," American Academy of Actuaries Risk Classification Subcommittee of the Property/Casualty Products, Pricing, and Market Committee., November 15, 2002 "The first explanation relates to stress. People under stress are more likely to have auto accidents. They may be more easily distracted or not react as well to certain situations (the difference between an accident and a near-miss is often just a fraction of a second). Financial problems are a known cause of stress. Therefore, some people with poor scores are more likely to experience stress and thus more likely to incur losses," Sheffey wrote.209 "The second explanation relates to risk-taking behavior," he continued. "Different people have different aversions to risk. Some people like to skydive. Some people are afraid of the amusement park roller coaster. Some people will run a yellow light if it was yellow when they first saw it. Some people will stay under 55 on the highway. People who are more likely to take risks are more likely to get into serious financial difficulties (bankruptcies, liens, foreclosures, etc.) than those who are more risk averse. As the studies show, people who are more likely to take risks are also more likely to get into auto accidents. Therefore, some people with poor scores are more likely to engage in risky behavior and thus more likely to incur losses. Similar reasoning probably applies to homeowners insurance as well." "Neither, either, or both of these theories may be true for a particular individual. In some instances, financial difficulties might not be caused by risk-taking behavior, but will still produce stress. In other instances, however, it is the risk-taking behavior rather than stress that leads to a greater likelihood of loss," he wrote. 209 Sheffey letter, op. cit. Sheffey said another theory is that "credit history reflects personal responsibility" and that one who prudently manages one's finances is prudent and responsible in the realms of homes and cars as well.210 A derivation would be that financially stable people would be more likely to pay for a minimal loss themselves "because they have the financial wherewithal, rather than file a claim."211 Similarly, some insurers believe that financially stable individuals are likely to exhibit stability in many other aspects of their lives.212 Sheffey said Allstate was not aware of any research that supported these theories, but was emphatic that the risk-taking and stress theories were well supported by research. Key Factors For Insurers According to the American Insurance Association, here are some of the kinds of data from credit reports that are of most interest to insurance scoring models:
210 Insurance Information Institute, The Use of Credit Information as an Underwriting Tool in Personal Lines Insurance, Brookings Institution Presentation, February 27, 2003. 211 From an April 11, 2003 presentation by NAIC President and Arkansas Insurance Commissioner Mike Pickens, reported by AM Best on April 14, 2003. 212 Insurance Information Institute, The Use of Credit Information as an Underwriting Tool in Personal Lines Insurance, Brookings Institution Presentation, February 27, 2003. A Contrary View Birny Birnbaum executive director of the Council for Economic Justice in Austin, Texas has led the fight against insurance credit scoring. He continually has challenged industry assertions that it is fair, that there is a correlation between credit history and insurance, or that the studies supporting it were credible. "The 'evidence' supporting the correlation claim comes almost exclusively from insurers, insurer trade associations, and credit scoring vendors who refuse to divulge the methodology of their studies, details of the study results, and/or the underlying data for independent verification," Birnbaum wrote in a January 2003 report for the Ohio Civil Rights Commission.213 "For those studies about which some information is known, the industry claims become more suspicious. For example, Fair, Isaac and Company continues to bring out the Tillinghast 'study' as support for the correlation-even though the National Association of Insurance Commissioners Credit Reports subgroup dismissed the 'study' as 'counterproductive and misleading.'" Birnbaum said there is plenty of evidence to raise questions about the industry's correlation theory. For instance, while economic conditions vary greatly by geographic region, credit scoring models are developed on a national basis. One survey showed that in the fourth quarter of 2000, mortgage delinquencies in the South were almost 60% higher than in the West. "Consumers with high credit scores in a region with weak economic conditions were more likely to encounter problems than consumers with lower scores in a region with stronger economic conditions," Birnbaum wrote.214 213 Birnbaum, Birny, "Insurers' Use of Credit Scoring for Homeowners Insurance In Ohio: A Report For the Ohio Civil Rights Commission," January 2003 214 Id. Then, there is bankruptcy data. "If consumers who have filed for bankruptcy in the past five years are far more likely to have claims than consumers who have not filed for bankruptcies, then we would expect an increase in loss ratios if the number of bankruptcies increases dramatically. Personal bankruptcies did increase dramatically during the 1990's, yet private passenger auto insurance loss ratios declined. The following data show a negative correlation-just the opposite of the positive correlation claimed by the insurance industry," he wrote.215 Birnbaum argued that credit scoring allows insurers to price based on the profitability of the consumer, as opposed to the expected risk of loss. In sum, it provides a shortcut for underwriting and rating consumers by income. He said that other profitability factors include:
"redline," that is, target consumers based upon their economic profiles.216 Further, insurers' use of credit reports and credit scores have proved controversial for other reasons. Some companies have been accused of failing to provide consumers with "adverse action notices" informing them that they were being charged more for insurance because of information in their credit report. Other insurers have been accused of pulling the credit reports of spouses and even non-family housemates who were not included in the policy. But before discussing these issues, let's briefly examine the way in which auto insurers typically use credit reports.217 Silence Of The Agents Birnbaum said an important voice was not being heard: insurance agents. "There are hundreds of agents who want to come forward and tell why they are opposed to credit scoring, why credit scoring has worsened insurance availability, and how credit scoring has a disproportionate impact on poor and minority consumers. But they won't be here today because of their fear of reprisal by the insurance companies they represent. To hear from these agents, they must be given protection against these reprisals. To give you a sense of who these agents are, the following agent organizations have come out against credit scoring-National Association of State Farm Agents, National Association of Professional All-state Agents, and the United Farmers Agents Association.218 216 Id. 217 Birnbaum, "Insurance Credit Scoring: An Unfairly Discriminatory Practice," before the Michigan Insurance Committee, July 2003 218 Id. The Texas Study In a Jan. 31, 2005, Texas Insurance Commissioner Jose Montemayor said that his study found that credit scores were a reliable predictor future losses, "finding there was a strong relationship between credit scores and claims experience on an aggregate basis."219 "Prior to the study, my initial suspicions were that while there may be a correlation to risk, credit scoring's value in pricing and underwriting risk was superficial, supported by the strength of other risk variables," he wrote. If that proved to be the case, Montemayor said he would have effectively banned insurers' use of credit scores. "The study, however, did not support those initial suspicions," he wrote. "Credit scoring, if continued, is not unfairly discriminatory as defined in current law because credit scoring is not based on race, nor is it a precise indicator of one's race. Recall that not all minorities are in the worst credit score categories. Further, its use is justified actuarially and it adds value to the insurance transaction. Without a change in statute that disallows credit scoring as a matter of public policy, any action to ban may be tied up in court for several years, further frustrating public expectation. On the other hand, the study found a "consistent pattern of differences in credit scores among the different racial/ethnic groups. The average credit scores for Whites and Asians are better than those for Blacks and Hispanics. In addition, Blacks and Hispanics tend to be over-represented in the worse credit score categories and under-represented in the better credit score categories." It also found "a consistent pattern of differences in credit scores depending on an individual's age, with younger people having worse credit scores than older people. The best average credit scores are for individuals older than 70." 219 Jan. 31, 2005 letter by Jose Montemayor to Gov. Rick Perry, et al. www.tdi.state.tx.us/general/pdf/credit05sup.pdf; also see Dec. 31, 2004 study www.tdi.state.tx.us/general/pdf/creditall04.pdf It Started With Marketing The move to start using credit reports probably was in part due to effective marketing by the "Big Three" credit reporting agencies (CRAs). The pitch was that credit scores were a better predictor of future losses than were the insurers' customary methods at the time. To test this theory, some insurers provided CRAs with a list of customers, some of whom had losses. The CRAs would then append each customer's credit score and return the list. This allowed the insurers, using their own statistical tools, to correlate credit scores to losses. Most insurers became convinced that consumers with lower credit scores were more likely to have future losses. It used to be that car insurers only used "underwriting" criteria when deciding whether to grant insurance or how much to charge for it. "Underwriting" criteria includes age, driving record, geographic location, and type of car. But given their belief that credit scores were reliable predictors, insurers had to find a way to integrate credit scores into their "decisioning" models. To accomplish this, insurers had to create a whole new formula, or matrix. An example was the new approach taken in the late 1990s by The Progressive Corporation, which sells auto insurance in most states.220 Progressive traditionally had divided consumers into five "markets" or "tiers" based upon their predicted risk or future losses:
220 Information about Progressive's policies and practices was included in court filings in U.S. District Court for the Northern District of Florida (Gainesville Division), in Cathryn Smith, et al. v. The Progressive Corp., et al. (Case No. 1:00-CV-210-MMP). The lead attorney was Terry Smiljanich of James, Hoyer, Newcomer and Smiljanich, of Tampa, Fla. Again, in the old, pre-1997 system, it was purely underwriting criteria that placed you in one of these categories. Presumably, if you had a perfect driving record, and you were the right age, drove the right kind of car, and met the other driving-related underwriting criteria, you would get the Ultra-Preferred rate. The Progressive Matrix Under the new system, Progressive created its own insurance-credit scoring system that divided consumers into the same five categories. That is to say, Progressive did not obtain from the CRAs a traditional FICO score. Rather, Progressive developed its own proprietary scoring model. Progressive's scoring model would then examine the information in the consumer's credit report that it believed was most predictive of future loss, and rate the driver. The credit score was then blended or cross-matched with the consumer's underwriting status. If you had an Ultra-Preferred credit score and an Ultra-Preferred underwriting rating, you would get the Ultra-Preferred rate. However, it did not matter if you had a perfect driving record. If you did not have a top-notch credit score according to Progressive's proprietary model, you were not eligible for Progressive's Ultra-Preferred rate. Progressive put such emphasis on information in your credit report that a bad credit score "dragged you down faster" than a bad underwriting rating. To better understand the impact of credit scores and how they were cross-matched against the underwriting rating in order to rate consumers, take a look at the chart on page 239. The "A-E" row at the top, running left to right, represents the consumer's credit score, or "financial responsibility," with "A" being the best and "E" being the worst. The "A-G" row, running down the left side of the page, represents the consumer's underwriting rating or "value." As mentioned the five categories are:
The Progressive Matrix
Now compare that to the bottom left corner, describing a problem driver with the worst possible underwriting value ("G"), who still gets a regular — "Standard" rate — because his credit score is top-notch. Similarly, someone with the worst underwriting value, but with a good ("B") credit score, pays the Mid-Market rate — the same rate as the person we described above with the best driving-underwriting record and a subprime credit score. This Matrix underscored Progressive's apparent belief that the credit score was as good or better a predictor of future losses than its traditional underwriting criteria. This Matrix enabled Progressive and independent insurance agents to give preliminary quotes to drivers. If the consumers indicated they were interested in purchasing insurance at the given quote, Progressive (or the insurance agent in some instances) would seek to verify their driving and claims history by ordering a separate report from ChoicePoint. A spin-off of Equifax, ChoicePoint gathers publicly available data from federal, state and local courts, state motor vehicle departments, other state licensing agencies, and sometimes, voting records. Just as the CRAs receive data from their customers — the credit grantors — so does ChoicePoint receive regular reports from insurance companies on people who file insurance claims. This information is stored in its database, "Claims Loss Underwriting Exchange" or CLUE. A driving history (MVR) or CLUE report can affect the final quote given the consumer. (ChoicePoint and CLUE Reports are discussed in more detail below and in subsequent chapters.) Progressive officials testified they only applied this model to new customers, not to renewing customers. This apparently meant that if you were initially covered by Progressive when you had a good credit rating, it would not hurt your renewal rate if your credit score went down. But if the opposite were true — you signed up when you had a bad credit rating but had since improved it — you were stuck at the less favorable rate, unless you knew to ask to be re-rated. Although there is limited data about how each insurer uses credit reports, there is reason to believe many use them in a fashion similar to Progressive. They develop their own proprietary model for scoring credit report data and then cross-match it against traditional underwriting criteria. Adverse Action Notices Progressive's practices came to light because it was sued for not giving adequate adverse action notices. Rather than inform each consumer that their car insurance quote was higher because of data in their credit report, Progressive gave all customers a form letter stating that the company some-times uses credit reports, and that these reports "may" affect the premium. The lawsuit charged that a generalized form letter, telling all consumers that their premiums "may" have been affected, was not specific enough. (The lawsuit was pending at the time this book went to press.) The discovery in the case revealed that the FTC staff in 2000 advised Progressive that its generalized form letter was not specific enough to meet the FCRA's adverse action requirements. Even before that, the Independent Insurance Agents of America (IIAA) in 1997, said in a policy statement that its members were "not presently convinced that there exists a clear and relevant correlation between an individual's credit history and a consumer's actual or potential loss experience." The IIAA recommended that credit information only be used if "insurance companies prove to the satisfaction of state insurance regulators that there exists a direct and relevant correlation between an individual's credit history and actual loss experience." The IIAA also called on insurance commissioners to ensure that insurers' use of credit data does not result in race or sex discrimination. If insurers were to use credit scores, it was vital that adverse action notices be given when information causes a denial of coverage or increase in the rates, it concluded. ChoicePoint: Key Auto Insurance Player In recent years, ChoicePoint has emerged as the premier player in both auto insurance and homeowners insurance. In fact, one insurance official referred to ChoicePoint "as the only game in town" when it came to driving records. Starting as a spin-off of Equifax, ChoicePoint has grown dramatically in recent years. During 2002, the Company produced $753.0 million in core revenue, a 19% increase from $631.7 million in 2001. Operating profit before unusual items increased 21% in 2002, from $166 million in 2001 to $200.6 million in 2002.221 It has expanded in many directions. It services the insurance industry through its electronic data exchange network in which insurers provide claims data and ChoicePoint sells it back to insurers. This system in many ways mirrors the traditional credit reporting system presided over by Equifax, Experian, and Trans Union. Another key to ChoicePoint's success has been its ability to harvest public records maintained mainly by state and local governments-motor vehicle records, court records, licensing records, and voting records. In this area, ChoicePoint has moved aggressively to purchase smaller, local companies that specialized in public records-much the same way the Big Three CRAs bought up smaller credit bureaus and consolidated their hold over the market from the 1980s to the present. First, we'll look at ChoicePoint's driving-related information services. Then, we'll examine its property-related services. Remember, much of the consumer information maintained by ChoicePoint qualifies as a consumer report regulated by the Fair Credit Reporting Act. At the end of this chapter, we will provide contact information for obtaining your various CLUE reports, which you can now get once a year at no charge. 221 www.corporate-ir.net/ireye/ir_site.zhtml?ticker=CPS&script=2100 Driving: 'CLUE' & "MVR' Reports ChoicePoint serves as a clearinghouse for both insurance claims information through its CLUE Personal Auto database, and through its Motor Vehicle Records (MVR) service. CLUE stands for Comprehensive Loss Underwriting Exchange. "CLUE Personal Auto is a claim history information exchange that enables insurance companies to access prior claim information in the underwriting and rating process," ChoicePoint stated on its Web site. "CLUE Personal Auto reports contain up to five years of personal automobile claims matching the search criteria submitted by the inquiring insurance company. Data provided in CLUE reports includes policy information such as name, date of birth, and policy number; claim information such as date of loss, type of loss, and amounts paid; and vehicle information. More than 95 percent of insurers writing automobile coverage provide claims data to the CLUE Personal Auto database."222 ChoicePoint Codes & Categories In addition to the identifying information, the CLUE Personal Auto report typically features the following codes to denote who was at fault (if known):
222 www.choicepoint.com/business/pc_ins/us_5.html Another set of codes reflects the loss that was incurred:
A typical Personal Auto report lists the disposition of the claim (closed, open, or in "subrogation"), the amount paid and date of first payment, type of vehicle, vehicle identification number (VIN), and disposition of the vehicle (e.g., repaired, stolen, totaled, damaged, no compensation). 'Possible Related Claims' The Personal Auto report also may include information on "Possible Related Claims" (PRC) defined as a "match" between the consumer who the insurer is inquiring about, and other individuals at the same address. "PRC means there is a match found on the address and at least one other identical data element, such as driver's license, SSN, policy number or last name," ChoicePoint explained in its sample report.223 "ChoicePoint encourages the insurance company to resolutely determine if these claims relate to the subject on whom the search criteria is underlined." In other words, ChoicePoint "encourages" insurers to avoid misjudging consumers on the basis of mixed files or other inaccuracies. But in traditional credit reporting, as well as among law enforcement agencies using criminal history data exchanges, such nuances can be lost among users. Too often, once the user sees the data on the computer screen, a match is assumed, and the consumer is judged accordingly. 223 http://www.choicepoint.com/sample_rpts/CLUEAutoUnderwriter.pdf Similarly, the report can include "Possible Additional Drivers." ChoicePoint said it "encourages the insurance company to verify this information prior to making business decisions." At the top of the "Possible Additional Drivers" section, it reads, "Additional driver might not reside in household or be associated with insured. This information should be independently verified prior to use. This report is not a recommendation."224 Insurers wanting to investigate drivers also can order the following "supplemental reports:"
224 Ibid "Online access to driving records is available for 40 states and two provinces, and ChoicePoint continues to add to the list of states with online access," the company said on its Web site. It said the advantages of the MVR included a "single interface to all state Departments of Motor Vehicles," and "Standard input and output record format."225 A sample of a driving report, and an explanation of how to read it, was available at the ChoicePoint Web site.226 When compared with the traditional credit reporting agencies, ChoicePoint's CLUE reports were relatively new and had stayed under the radar screen. Thus, it had not been subjected to the same level of public scrutiny. To date, there has been no independent assessment of the accuracy of data in ChoicePoint's varying and large and growing databases. Harbinger, Or Fluke? There was abundant reason to believe that ChoicePoint would experience the same inaccuracy issues as its brethren in the credit reporting industry. For example, in one case, an insurer raised a consumer's auto insurance premium based upon a ChoicePoint report of a traffic citation, even before the court rendered a decision on the citation. The consumer disputed the inaccuracy, pointing out that the citation had not even been adjudicated. But ChoicePoint said it was merely passing on information, serving as an electronic go-between the insurance companies and the Department of Motor Vehicles (DMV). ChoicePoint said it could not correct the information because it was not responsible for it. Only the DMV could correct it, ChoicePoint argued. Like so many other issues involving personal information, the question of which entity is responsible for ensuring accuracy under the FCRA will have to be decided by the courts. 225 http://www.choicepoint.com/business/pc_ins/us_5.html 226 http://www.choicepoint.com/sample_rpts/mvrhowtoread.pdf How To Obtain Your CLUE Reports Under the 2003 amendments to the FCRA, known as the "Fair and Accurate Credit Transactions Act (FACT Act)," consumers are entitled one free copy of their consumer file during each 12-month period. ChoicePoint said it has three "products" that are free under the FACT Act: the C.L.U.E. (auto and homeowners insurance); "WorkPlace Solutions" (employment background screening) and "Tenant History" (apartment rentals). You can order these online, via toll free phone number, or through the mail. Here's the contact information: www.choicetrust.com C.L.U.E. Auto or Homeowners Reports ChoicePoint Consumer Disclosure Center P.O. Box 105295 Atlanta, GA 30348 1-(866) 312-8076 WorkPlace Solutions ChoicePoint Consumer Disclosure Center P.O. Box 105292 Atlanta, GA 30348 1-(866) 312-8075 Tenant History Resident Data Consumer Disclosure Center P.O. Box 850126 Richardson, TX 75085-0126 1-(877) 448-5732 ChoicePoint said there would be no C.L.U.E report on you if you had not filed an auto or home insurance during the last five years. However, it also said it would not have an employment history or tenant history report "if you have not applied for employment with a customer that we serve," or "have not submitted a residential lease application with a customer that we serve."227 How could it not have a "report" on you, but then sell one to an employer or landlord when they asked for it? Under ChoicePoint's interpretation, you apparently could not check the accuracy of a report before it was sold to a landlord or employer. But the FCRA requires that every CRA shall, upon request, disclose to the consumer "all information in the consumer's file." This fundamental question of access might have to be decided by the courts. Unregulated Data? In addition, ChoicePoint claimed that other consumer data it sold was not subject to the FCRA and therefore need not be disclosed to consumers. This is because the company and its subsidiaries tap a wide range of taxpayer-subsidized sources, including local property records; driver records; boating, pilot and professional licenses; and court records showing bankruptcies, liens, judgments and divorce. The company had accumulated 19 billion records with personal data, according to media reports. It was not entirely clear how ChoicePoint organized and "housed" all of the information. But presumably much of it was out of reach to the average consumer. That meant you could not see your data or correct errors — even though other companies and government agencies could buy the same data and use them for making decisions about you. 227 www.choicepoint.com/factact.html, visited March 13, 2005 The Electronic Privacy Information Center challenged ChoicePoint's claims of not being regulated by any federal law, particularly for its "AutoTrackXP," which "locates and verifies assets" or helps investigate fraud, and for its "Customer Identification Programs," which mainly help banks verify the identities of new customers. As this book went to print in March 2005, momentum was building in Congress to give consumers stronger rights, akin to the FCRA, in relation to non-credit database companies like ChoicePoint, LexisNexis/Seisint, Westlaw and Acxiom. At a March 15, 2005 hearing before the Senate Banking Committee, Sen. Charles Schumer (D-NY) told a ChoicePoint executive that given the company's poor performance in preventing identity theft, it did not belong in the business of selling personal information. Citing the Mary Boris case (see next chapter), Sen. Jim Bunning (R-KY) castigated ChoicePoint for its inability to protect sensitive information like Social Security numbers. "And this is information you probably should not be selling in the first place," said Bunning, an advocate of greater protection for SSNs.228 228 "Identity Theft: Recent Developments Involving the Security of Sensitive Consumer Information," Senate Banking Committee hearing, March 10 & 15, 2005 http://banking.senate.gov/index.cfm?Fuseaction=Hearings.Detail&HearingID=144 and http://banking.senate.gov/index.cfm?Fuseaction=Hearings.Detail&HearingID=142 © 2005 Evan Hendricks and Privacy Times, Inc. All rights reserved. |
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