Proposal to Enhance Efficiency of SSN Assignment

-----Original Message----- From: firstgadfly@comcast.net [mailto:firstgadfly@comcast.net] Sent: Wednesday, July 11, 2007 11:13 AM To: ^Regulations Subject: Proposal to Enhance Efficiency of SSN Assignment The rationale for randomizing assignment of SSNs set out in Section B of your Federal Register announcement of July 3, 2007, appears to be well thought through. However, the rationale set out in Section C, concerning protection against identity theft leaves much to be desired. A potential identity thief would need to know both the name of the SSN holder and the full SSN before being able to initiate additional action needed to assume the SSN holder's identity. If those two items are known to the potential thief, this proposal would not serve to accomplish the objective of Section C. It seems too much of a stretch of the imagination to expect that anyone who knows an area code issued under the current system for SSN assignment to acquire sufficient information from that datum to be able to steal the identity of any individual among the potential one million people (group numbers times serial numbers) to whom the SSNs were issued. Among other considerations is the fact that virtually no one can do better than crudely approximate the issuance date of an SSN by reference to the group number unless he or she is a current or former employee of SSA with intimate knowledge of the issuance process. As a practical matter, there is no way a full SSN can be either inferred or deduced from the area number. Given that the Section B rationale is sufficient justification for taking the proposed action and that the Section C justification appears to be flawed, I recommend that the Section C argument be deleted from the final document. Section C seems weak, confusing and unnecessary to the overall purpose of the proposal. Respectfully, David C. Greenwald