ARLINGTON, Va. — In response to a request for comments to the Federal Trade Commission following up on a recommendation by the President's Identity Theft Task Force, NAFCU said credit unions' use of Social Security numbers is essential but fiercely protected.

"The credit union industry is firmly committed to combating identity theft–a reprehensible crime that ruins victims' good names and costs time and money for financial institutions. The credit union community is extremely vigilant in guarding its members against identity theft," NAFCU Senior Vice President of Government Affairs Dan Berger said in a letter to the FTC.

NAFCU pointed out that credit unions generally have to use SSNs from their members to comply with the identity verification section of the Bank Secrecy Act and USA PATRIOT Act. "Additionally, credit unions must collect SSNs when fulfilling their BSA/AML reporting obligations," the letter highlighted. "For example, the SSN is required on Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR)." SSNs are also used to aggregate transactions to monitor for structuring or other suspicious activity and check people against government lists, such as the Office of Foreign Assets Control's sanctions listing.