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In 2018, Congress passed the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). This law included a section (Sec. 215) “to reduce the prevalence of synthetic identity fraud, which disproportionally affects vulnerable populations, such as minors and recent immigrants, by facilitating the validation by permitted entities of fraud protection data, pursuant to electronically received consumer consent, through use of a database maintained by the [SSA] Commissioner.” Sec. 215(a).
CDIA, on its own, and as part of a coalition of allied trade groups, worked with SSA to help it SSA implement and execute the SSA’s electronic Consent Based Social Security Number (“SSN”) Verification (“eCSBV“) system.
In April 2021, the SSA issued a Federal Register notice on agency collection activities under the Paperwork Reduction Act (PRA) for the eCBSV service. As established in the notice,
This information collection request is for the expanded rollout of eCBSV. The previous eCBSV clearance was for an initial rollout to 10 selected permitted entities. During the initial rollout, we wanted to troubleshoot the service and make any necessary adjustments prior to opening eCBSV to all permitted entities. The respondents to the eCBSV information collection are the permitted entities; members of the public who consent to SSN verifications; and CPAs who provide compliance review services.
A coalition of allied trade associations, including CDIA, filed a comment in connection with that OMB notice and a follow-up comment in May 2021.
In March 2020, the SSA issued a Federal Register notice on its Revised Draft User Agreement for participants in the eCBSV system, and later that same month A coalition of allied trade associations, including CDIA, filed a comment in connection with that OMB notice.
In March 2020, the SSA issued a Federal Register notice under the PRA. A coalition of allied trade associations, including CDIA, filed a comment in connection with that OMB notice.
Additional Resources:
- 2020 11 03 – Letter to SSA
- 2020 11 30 – Letter from SSA
- 2020 02 24 – Joint Trades Letter
- 2019 12 23 – SSA – ABA-CFC-SSA FRN Comments
- 2019 10 24 – SSA – Reply to Joint Trades Letter
- 2019 10 10 – Joint Trades Letter
- 2019 02 05 – SSA ESIGN joint trades
- 2022 01 14 – SSA Federal Register Notice of Open Enrollment and Fee Increase for Our Electronic Consent-Based Social Security Number Verification Service
- 2022 04 12 – Coalition Letter to SSA on Tier Fee Schedule
- 2022 08 17 – SSA Response Re eCBSV Tier Fee Schedule
- 2022 09 – Sen. Scott, Crapo Letter to GAO 2022 09 – Sen. Scott, Crapo Letter to GAO
- 2022 11 01 – GAO Letter to Sen. Tim Scott (R-SC) on a GAO Study
- SSA built a system to help combat identity fraud. Backers say it’s ‘at risk of collapse’, (June 30, 2023).