This is an official notice of the National Council of Investigation & Security Services representing the investigative and security professions for 39 years

 

Capitol
NCISS 
Legislative Alert
March 26, 2014
 

 

Death Master File UPDATE

  

 

UPDATE ON DEATH MASTER FILE

 

There have been a myriad of messages circulating in the last couple of days regarding applying for and/or accessing the Death Master SSN file (DMF). I know you have been as alarmed as I have been. 

 

I contacted IRB, Tracers and TLO. This is what I know after talking to a management representative at IRB, I have not yet heard back from TLO and Tracers. 

 

1. The certification requirement is for the data providers, not necessarily for individual private investigators. 

 

2. The data providers know about the certification and are doing their best to comply.

 

3. The DMF certification requirement will not impact the information that is already in each of the data provider's data bases. Access to those files will continue to be available. 

 

4. The certification is required for any current additions to the DMF. 

 

5. Until each data provider application is approved there will be a lapse in the data providers getting the new data from the DMF. 

 

6. In the event a data provider is not approved, the information will be still available in about three years. It evidently takes social security three years to update all of the files to show "deceased" on the file due to the number of deaths every year. Social Security wants to ensure that the file on a deceased person is so noted due to the use of deceased persons for identity theft. 

 

7.  Once the data provider is approved, data provider clients should be able to access data as a subscriber. 

 

7. It is still unknown if the data providers will be required to have additional "permissible purpose" criteria to receive the new data. 

 

                                                    ~~~~~~~~~

 

On February 20, I sent the following communique to all of you from our legislative advocates at Lobbyit. The process is still evolving. 

 

 ADVANCE NOTICE - COMMERCE DEPARTMENT

 "HEARING" ON DEATH MASTER FILE

 

Though not yet publicly announced, the Commerce Department is expecting to hold a hearing, or "listening session" on the development of the regulations for access to the Death Master File (DMF) on or about March 4 in Crystal City, Va.  Commerce will be on "receive" during this hearing, and are soliciting input from affected parties prior to the development of the proposed rule.

 

Pursuant to the statute, Commerce must issue regs within 90 days of the law's ratification.   Consequently, by law a rule must issue by March 26.

 

Commerce does not believe, however, that this 90 day period is sufficient to craft a proper rule, and therefore expects to issue an "interim final" rule by March 26. 

 

This interim final rule will then be open for public comment.

 

~~~~~~~~~

 

I hope this answers your questions. I will provide additional information as soon as I have it. If you have questions, please do no hesitate to contact me, I will do my best to get the answer for you. 

Francie Koehler

 

 Francie Koehler

NCISS Legislative Chair

7501 Sparrows Point Boulevard

Baltimore, Maryland 21219-19

27

T-(800) 445-8408  F-(410) 388-9746

www.nciss.org

  

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