Advanced Reporting

As you order your background checks this holiday season remember that many sources, particularly courts and educational institutions, may have extended closures scheduled.  Your Advanced Reporting team is working hard to minimize the impact of these service limitations on you.  If you have any questions about the availability of certain sources please don’t hestitate to give us a call.

Effective November 1, 2011, the Death Master File provided by the Social Security Administration (SSA) will no longer contain protected state death records.  Why did the SSA make this change? The SSA receives death reports from various sources, including family members, funeral homes, hospitals and financial institutions.  As of November 1, 2011, the SSA will no longer include certain protected state death records in the Death Master File (DMF) it distributes through the National Technical Information Service (NTIS) for the following reason:

• Section 205(r) of the Social Security Act prohibits the SSA from disclosing state death records the SSA receives through its contracts with the states, except in limited circumstances.

The content of the DMF, provided by the SSA, will be altered as follows:

• The historical Public DMF contains 89 million records. SSA will remove approximately 4.2 million records from this repository.
• In the previous year, 2010, the SSA shared roughly 2.8 million death records through the DMF. This number will be reduced by roughly 1 million records each year going forward.

  Note: Per both the SSA and NTIS, users of the DMF should always investigate and verify the death listed in the file before taking any adverse action against any individual.

Advanced Reporting will be in Bellevue, WA on Wednesday 10/5 and Thursday 10/6 at the Northwest Human Resource Management Association Annual Conference, in Woodburn, OR on Wednesday 10/5 at the Silverton Hospital Business Health Services Annual Health & Safety Conference and in Salem, OR representing Cooperative Payroll Solutions on Friday 10/7 at Oregon’s Annual Payroll Statewide Conference.  If you are going to be attending any of these events please come find us, say hi and enter to win one of our drawings.

Criminal background checks used to screen teacher applicants, doctors, nurses and daycare employees may not turn up their arrest records because of critical gaps in the Texas criminal records database, a new state audit shows. Prosecutors and courts have failed to submit to the state disposition records on about one of every four arrests in 2009.

Good news, the SSA has reduced the fees for using the Consent Based Social Security Number Verification (CBSV) service and we’re passing those savings directly to you.  CBSV verifies whether a name and Social Security Number (SSN) combination match the data in SSA records. The submitted information is matched against SSA Master File of Social Security Numbers (SSNs). Each SSN and name combination submitted to CBSV will be returned with a ”yes” or ”no” verification code that the submission either matches or does not match SSA records. Pursuant SSA program requirements, CBSV requires the written consent of the SSN holder and the verification results can only be used for the reason the number holder specifies.  For more information about incorporating this search into your screening program please call us today.

Advanced Reporting currently is seeking a part-time Background Investigation Processor to join our screening team.  The entry-level position is a great opportunity to learn about the screening industry from an experienced team of professionals. For more information or to apply visit the Maps Credit Union Careers site or contact us at info@advrep.com.  Advanced Reporting is a wholly owned subsidiary of Maps Credit Union.

Among the many changes enacted as a part of last year’s Dodd-Frank Wall  Street Reform and Consumer Protection Act (Public Law 111-209) (Dodd- Frank) is an amendment to the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et. seq., which will require any person (not only creditors) that uses a credit score to take an adverse action against a consumer to make additional disclosures to consumers as part of the adverse action notice already required by FCRA Section 615(a), 15 U.S.C. § 1681m(a).  This new requirement is scheduled to become effective on July 21, 2011, which has been established as the “designated transfer date” for the transfer of functions under various consumer protection laws, including the FCRA, to the new Consumer Financial Protection Bureau (CFPB).    Existing FCRA Adverse Action Notice Requirements FCRA Section 615(a) currently requires any person that uses information contained in a consumer report to take an adverse action against a consumer to provide the consumer with oral, written, or electronic notice of that adverse action, including information such as:

• Contact information for the consumer reporting agency that provided the consumer report;
• A statement that the consumer reporting agency did not make the decision to take the adverse action and is unable to provide the consumer with the specific reasons for the action;
• Information about the consumer’s right under the FCRA to obtain a free copy of their consumer report from the consumer reporting agency if they request it within 60 days of receiving the notice; and the consumer’s right to dispute the accuracy or completeness of information with the consumer reporting agency.

The New Dodd-Frank Requirements Section 1100F of Dodd-Frank expands the above listed existing adverse action notice requirements to require any person that takes an adverse action based in whole or in part on a numerical credit score to also provide written or electronic (unlike the current requirements, oral disclosure would be insufficient) disclosure of the credit score.  The following information about the credit score also would need to be disclosed to the consumer by the user of the consumer report (who may need to obtain it from a consumer reporting agency if that is the source of the credit score):

• The range of possible credit scores under the model used;
• The date on which the credit score was created;
• The name of the person or entity that provided the credit score or the credit file used to create the credit score; and

The key factors, listed in order of importance, which adversely affected the score of the consumer in the model used.

 On Friday July 15^th 2011 the State of Colorado discovered an error in the Driver’s License update process that began on  July 10^th 2011 that was preventing updates from being reliably applied to the Driver’s License Database.  In order to assure that you are being presented with the most accurate records possible, the DMV decided to restore the database to its state as of July 9^th 2011 and suspend further updates until the issue can be resolved. Once the issue has been resolved and normal operations have been restored the state will review application logs and notify us if any records retrieved by your company may have been impacted by this issue.

On May 9, 2011 the US Federal Trade Commission (FTC) concluded it’s investigation of Social Intelligence Corporation, a company aggregating social media information on consumers for use in background screening.  The FTC concluded that the information gathered from social networking sites is public information and that Social Intelligence Corporation is a consumer reporting agency and, as such, must comply with the provisions of the Fair Credit Reporting Act (FCRA).  This closing letter by the FTC opens the door for FCRA compliant social media searches in the background screening process.

The Social Security Administration (SSA) is changing the way Social Security Numbers (SSNs) are issued. This change is referred to as “randomization.” On July 3, 2007, the SSA published its intent to randomize the nine-digit SSN in the Federal Register Notice, Protecting the Integrity of Social Security Numbers [Docket No. SSA 2007-0046]. The date for SSN Randomization was announced as June 25, 2011 to coincide with the start of the third quarter and software updates. The SSA is developing this new method to help protect the integrity of the SSN and extend the longevity of SSNs in all states. The SSA began assigning the nine-digit SSN in 1936 for the purpose of tracking workers’ earnings over the course of their lifetimes to pay benefits. Since its inception, the SSN has always been comprised of the three-digit area number, followed by the two-digit group number, and ending with the four-digit serial number. There are approximately 420 million numbers available for assignment. However, the current SSN assignment process limits the number of SSNs that are available for issuance to individuals by each state. SSN Randomization will affect the SSN assignment process in the following ways:

• It will eliminate the significance of the highest group number and, as a result, the High Group List will be frozen in time and can only be used for validation of SSNs issued prior to the randomization implementation date. 
• It will eliminate the geographical significance of the first three digits of the SSN by no longer allocating the area numbers for assignment to individuals in specific states.
• Previously unassigned area numbers will be introduced for assignment (“7″ and “8″ in the first position) excluding area numbers 000, 666 and 900-999.  

Using these ranges of numbers will allow SSA to continue issuing SSNs for approximately the next 30 years without making any changes, but these changes to the SSN may require systems and/or business process updates to accommodate SSN Randomization. Over 95% of new SSN cards issued each year are to newborns (the SSA Enumeration at Birth process), but there will be adults with randomized SSNs this week. Under the following circumstances, the SSA may assign a new number:   

• Sequential numbers assigned to members of the same family are causing problems;
• More than one person is using the same number;
• An individual has religious or cultural objections to certain numbers or digits in the original number;
• A victim of identity theft continues to be disadvantaged by using the original number;
• Situations of harassment, abuse or life endangerment (including domestic violence)

With SSN Randomization, please let us know if you are interested in learning more about the Consent Based Social Security Number Verification (CBSV) service for verification purposes to mitigate fraud and identity theft and its associated losses. SSN Trace algorithms will no longer be useful and some old methods of validation will be obsolete.