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	<title>Comments on: Instant Credit Income Verification: A Retail IT Migraine On The Horizon?</title>
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	<description>Techniques, Tools and Tirades about Retail Technology and E-Commerce</description>
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		<title>By: Chris Phillips</title>
		<link>http://storefrontbacktalk.com/securityfraud/instant-credit-income-verification-a-retail-it-migraine-on-the-horizon/comment-page-1/#comment-64243</link>
		<dc:creator>Chris Phillips</dc:creator>
		<pubDate>Mon, 14 Dec 2009 17:53:47 +0000</pubDate>
		<guid isPermaLink="false">http://www.storefrontbacktalk.com/?p=4404#comment-64243</guid>
		<description>We may be saying the same thing, or we may not.  The requirements to consider income and liabilities is certainly a huge impediment to instant issue credit cards. Thoughtful concerns have been and are being lodged with the Fed. These rules (to me) seem to be solutions in search of a problem.  Failure of consumers to repay private label credit cards did not cause the current crisis.  Mortgage companies are now required to verify income, which seems somewhat more on target.

But in terms of information collected, I don&#039;t think issuers want to verify it unless the Fed requires them to - and if they do want to verify it, they are probably already doing so (at one time Amex required 1040s for credit issuance, and may still do so for some cards).  

The consumer will have to fill out an application (paper, terminal or verbal) just as they do now, and, just as they do now, the information from the application will have to get into the system.  Your question about how this information is communicated (verbally?) is certainly one of the thorny issues that issuers have raised, but to someone wanting to steal my identity, my income level is a lot less important than my DOB, DL# or SSN, at least a couple of which are already in the system.  I&#039;m not sure that information about income or liabilities is qualitatively different than what is currently collected and not any huge quantitative leap.  

My original comment and this response is in no way intended as confrontational, I&#039;m just pointing out that verification isn&#039;t currently proposed, and I don&#039;t think most retailers intend to do it. I&#039;d certainly be interested to hear of issuers with plans to the contrary.</description>
		<content:encoded><![CDATA[<p>We may be saying the same thing, or we may not.  The requirements to consider income and liabilities is certainly a huge impediment to instant issue credit cards. Thoughtful concerns have been and are being lodged with the Fed. These rules (to me) seem to be solutions in search of a problem.  Failure of consumers to repay private label credit cards did not cause the current crisis.  Mortgage companies are now required to verify income, which seems somewhat more on target.</p>
<p>But in terms of information collected, I don&#8217;t think issuers want to verify it unless the Fed requires them to &#8211; and if they do want to verify it, they are probably already doing so (at one time Amex required 1040s for credit issuance, and may still do so for some cards).  </p>
<p>The consumer will have to fill out an application (paper, terminal or verbal) just as they do now, and, just as they do now, the information from the application will have to get into the system.  Your question about how this information is communicated (verbally?) is certainly one of the thorny issues that issuers have raised, but to someone wanting to steal my identity, my income level is a lot less important than my DOB, DL# or SSN, at least a couple of which are already in the system.  I&#8217;m not sure that information about income or liabilities is qualitatively different than what is currently collected and not any huge quantitative leap.  </p>
<p>My original comment and this response is in no way intended as confrontational, I&#8217;m just pointing out that verification isn&#8217;t currently proposed, and I don&#8217;t think most retailers intend to do it. I&#8217;d certainly be interested to hear of issuers with plans to the contrary.</p>
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		<title>By: Evan Schuman</title>
		<link>http://storefrontbacktalk.com/securityfraud/instant-credit-income-verification-a-retail-it-migraine-on-the-horizon/comment-page-1/#comment-64241</link>
		<dc:creator>Evan Schuman</dc:creator>
		<pubDate>Mon, 14 Dec 2009 13:35:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.storefrontbacktalk.com/?p=4404#comment-64241</guid>
		<description>Editor&#039;s Note: The story didn&#039;t contradict that. But if you think this through, how would this likely work? Is a cashier--in front of everyone--supposed to ask this? And those same associate cashiers are given strong incentives for speed, to keep the line moving. Is not a quick peek at a document more confidential and faster? Even if it&#039;s solely verbal--which seems unlikely--what is the associate supposed to do with that? Wouldn&#039;t it be more likely that they would have to write it down or enter it somewhere? For management purposes only, there has to be some kind of record. And the capturing of that data is what the story was discussing. The last thing any major chain would want to do is blatantly follow the letter of the rule and not the spirit. For the moment, we stand by the concerns and issues raised in the story.</description>
		<content:encoded><![CDATA[<p>Editor&#8217;s Note: The story didn&#8217;t contradict that. But if you think this through, how would this likely work? Is a cashier&#8211;in front of everyone&#8211;supposed to ask this? And those same associate cashiers are given strong incentives for speed, to keep the line moving. Is not a quick peek at a document more confidential and faster? Even if it&#8217;s solely verbal&#8211;which seems unlikely&#8211;what is the associate supposed to do with that? Wouldn&#8217;t it be more likely that they would have to write it down or enter it somewhere? For management purposes only, there has to be some kind of record. And the capturing of that data is what the story was discussing. The last thing any major chain would want to do is blatantly follow the letter of the rule and not the spirit. For the moment, we stand by the concerns and issues raised in the story.</p>
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		<title>By: Chris Phillips</title>
		<link>http://storefrontbacktalk.com/securityfraud/instant-credit-income-verification-a-retail-it-migraine-on-the-horizon/comment-page-1/#comment-64239</link>
		<dc:creator>Chris Phillips</dc:creator>
		<pubDate>Mon, 14 Dec 2009 04:40:01 +0000</pubDate>
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		<description>I think this post is mostly based on misconceptions about the Fed proposal.  While the Reg Z proposed rule is certainly a problem for instant issue private label credit, the Fed was quite careful to point out that no verification would be required for income data provided by the consumer.  Issuers have to ask about income and they have to consider income (and liabilities), but they don&#039;t have to verify. That could change in the final regs, but it&#039;s not on the table now.</description>
		<content:encoded><![CDATA[<p>I think this post is mostly based on misconceptions about the Fed proposal.  While the Reg Z proposed rule is certainly a problem for instant issue private label credit, the Fed was quite careful to point out that no verification would be required for income data provided by the consumer.  Issuers have to ask about income and they have to consider income (and liabilities), but they don&#8217;t have to verify. That could change in the final regs, but it&#8217;s not on the table now.</p>
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		<title>By: James Loar</title>
		<link>http://storefrontbacktalk.com/securityfraud/instant-credit-income-verification-a-retail-it-migraine-on-the-horizon/comment-page-1/#comment-64226</link>
		<dc:creator>James Loar</dc:creator>
		<pubDate>Thu, 10 Dec 2009 15:27:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.storefrontbacktalk.com/?p=4404#comment-64226</guid>
		<description>1- Who ever carries around their pay-stub or tax return?
2- This would be a great means to kill off the credit concept and force people to only buy what they can afford - in cash.  Maybe that&#039;s the real goal?</description>
		<content:encoded><![CDATA[<p>1- Who ever carries around their pay-stub or tax return?<br />
2- This would be a great means to kill off the credit concept and force people to only buy what they can afford &#8211; in cash.  Maybe that&#8217;s the real goal?</p>
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