# Agency Information Collection Activities: Comment Request
The Social Security Administration (SSA) publishes a list of information collection packages requiring clearance by the Office of Management and Budget (OMB) in compliance with Public Law 104-13, the Paperwork Reduction Act of 1995, effective October 1, 1995. This notice includes one new collection.
SSA is soliciting comments on the accuracy of the agency's burden estimate; the need for the information; its practical utility; ways to enhance its quality, utility, and clarity; and ways to minimize burden on respondents, including the use of automated collection techniques or other forms of information technology. Mail, email, or fax your comments and recommendations on the information collection(s) to the OMB Desk Officer and SSA Reports Clearance Officer at the following addresses or fax numbers.
(OMB), Office of Management and Budget, Attn: Desk Officer for SSA, Fax: 202-395-6974, Email address: *[email protected]*
(SSA), Social Security Administration, OLCA, Attn: Reports Clearance Director, 3100 West High Rise, 6401 Security Blvd., Baltimore, MD 21235, Fax: 410-966-2830, Email address: *[email protected]*
Or you may submit your comments online through *www.regulations.gov,* referencing Docket ID Number [SSA-2020-0011].
SSA submitted the information collection below to OMB for clearance. Your comments regarding this information collection would be most useful if OMB and SSA receive them 30 days from the date of this publication. To be sure we consider your comments, we must receive them no later than April 9, 2020. Individuals can obtain copies of the OMB clearance package by writing to *[email protected].*
*Electronic Consent Based Social Security Number Verification—20 CFR 400.100—0960-NEW* . The electronic Consent Based Social Security Number Verification (eCBSV) is a fee-based Social Security Number (SSN) verification service that will allow permitted entities (a financial institution or service provider, subsidiary, affiliate, agent, subcontractor, or assignee of a financial institution as defined by Section 509 of the Gramm-Leach-Bliley Act, 42 U.S.C.A. 405b(b)(4), Pub. L. 115-174, Title II, 215(b)(4)) to verify an individual's SSN based on the SSN holder's signed consent in connection with a credit transaction or any circumstance described in section 604 of the Fair Credit Reporting Act (15 U.S.C. 1681b).
**Background**
We are creating this system due to section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (Banking Bill), Public Law 115-174. Permitted entities will be able to submit an SSN, name, and date of birth (DOB) to SSA for verification via an application programming interface. The purpose of the information collection is for SSA to verify for the permitted entity that the submitted name, DOB, and SSN matches, or does not match, the data contained in our records. After completing the enrollment process, paying for services, and obtaining SSN holder consent, the permitted entity submits the names, DOBs, and SSNs of number holders who gave valid consents to the eCBSV service. SSA matches the information against our Master File, using SSN, name, and DOB. The eCBSV Service will respond in real time with a match/no match indicator (and an indicator if our records show that the SSN Holder died). SSA does not provide specific information on what data elements did not match, nor does SSA provide any SSNs or other identifying information. In addition, the verification does not authenticate the identity of individuals or conclusively prove the individuals we verify are who they claim to be.
**Consent Requirements**
Under eCBSV, the permitted entity does not submit the number holder's consent documents to SSA. SSA requires each permitted entity to retain a valid consent for each SSN verification request for a period of five years from the date of receipt of the consent form. The Banking Bill permits a Financial Institution's service provider, subsidiary, affiliate, agent, subcontractor, or assignee to seek verification of the SSN Holder's SSN on behalf of a financial institution pursuant to the terms of the SSN Holder's consent. In this case, the permitted entity shall ensure that the Financial Institution use the verification only for the purposes stated in the consent, and make no further use or disclosure of the verified SSN. The relationship will be subject to the contractual obligations as specified in the User Agreement with which the permitted entity must concur.
**Compliance Review**
SSA requires each permitted entity to undergo compliance reviews to ensure the permitted entities obtained valid consent from number holders. An SSA approved certified public accountant (CPA) firm will conduct the compliance reviews. The reviews will ensure the permitted entities meet all terms and conditions of the User Agreement. The eCBSV fee will include all compliance review costs. In general, all eCBSV users will be subject to an audit within the first three years after they begin using the system, with subsequent additional reviews to be conducted periodically afterward. The CPA follows review standards established by the American Institute of Certified Public Accountants and contained in the Generally Accepted Government Audit Standards (GAGAS). At any time, SSA may conduct onsite inspections of the requester's site, including a systems review, to ensure they adhered to the applicable requirements associated with collection and maintenance of consent forms, and to assess systems security overall.
The respondents to the eCBSV collection are the permitted entities; members of the public who consent to the SSN verification; and CPAs who provide compliance review services.
*Type of Request:* Request for a new information collection.
**Note:**
Anyone who wishes to see revised versions of the draft ICR collection instruments, an explanation of the changes SSA made to these draft instruments, and all other ICR documents (including the Supporting Statement and summary of public comments) may do so at *https://www.ssa.gov/dataexchange/eCBSV/index.html* beginning from the morning of publication of this notice.
**Time Burden**
| Requirement | Number of | Frequency of response | Average | Estimated total annual burden (hours) | Average | Total annual |
| --- | --- | --- | --- | --- | --- | --- |
| (a) Complete eCBSV enrollment process *** | 10 | 1 | 120 | 20 | * $36.98 | ** $740 |
| (a) Configure customer system for ability to send in verification requests | 10 | 1 | 2,400 | 400 | * 36.98 | ** 14,792 |
| (a) People whose SSNs SSA will verify—Reading and Signing | 307,000,000 | 1 | 3 | 15,350,000 | * 10.22 | ** 156,877,000 |
| (a) Sending in the verification request, calling our system, getting a response | 307,000,000 | 1 | 1 | 5,116,667 | * 36.98 | ** 189,214,346 |
| (b) Follow SSA requirements to configure application program interface | 10 | 1 | 4,800 | 800 | * 36.98 | ** 29,584 |
| (c) CPA Compliance Review and Report **** | 10 | 1 | 4,800 | 800 | * 33.89 | ** 27,112 |
| Totals | 614,000,040 | | | 20,468,687 | | ** 346,163,574 |
**Cost Burden**
The public cost burden is dependent upon the number of permitted entities and annual transaction volume. In FY 2019, 10 companies enrolled out of 123 applications received to participate in eCBSV. We based the cost estimates below on 10 participating permitted entities in FY 2020 submitting an anticipated volume of 307,000,000 transactions. The Banking Bill requires that we collect at least 50 percent of the start-up costs ( *i.e.,* that we collect $9.2 million) before we may begin development of the eCBSV verification system. SSA will recover the remaining development costs over three years using the following tier fee schedule:
| Tier | Volume threshold | Annual fee |
| --- | --- | --- |
| ( | 1-1,000 | $400 |
| ( | 1,001-10,000 | 3,030 |
| ( | 10,001-200,000 | 14,300 |
| ( | 200,001-50 million | 276,500 |
| ( | 50,000,001-2 billion | 860,000 |
Each enrolled permitted entity will be required to remit the above tier based subscription fee for the 365-day agreement period and the appropriate administrative fee. We will charge newly enrolled entities a startup administrative fee of $3,693. After the initial year, we will charge the entities a renewal administrative fee of $1,691 each time the agreement is renewed or amended. We calculated the fees based on forecasted systems and operational expenses; agency oversight, overhead and CPA audit contract costs.
In addition, SSA will periodically recalculate costs to provide eCBSV services and adjust the fees charged as needed. We will notify companies of a fee adjustment at the renewal of the eCBSV User Agreement and via notice in the *Federal Register* ; companies have the opportunity to cancel the agreement or continue service using the new fee.
Dated: March 5, 2020.
Faye I. Lipsky,
Director, Office of Regulations and Reports, Clearance, Social Security Administration.