Remarks of Thomas E. Wolfsohn
Senior Vice President of
Government Affairs and Communications
American Association of Motor Vehicle
Administrators (AAMVA)
NCSL ID Security FSL Partnership Project
May 1,
2004
Fraudulently obtained driver's licenses:
- Are a significant factor in highway deaths and injuries,
- Facilitate identity fraud and identity theft-the fastest growing crime in
the U.S., and
- Threaten homeland security.
Improving the security of the state issued driver's license document and the
integrity of the issuance process will:
- Improve highway safety throughout the U.S.
by targeting dangerous drivers who obtain multiple driver's licenses, spread
their convictions from state-to-state, and injure and kill innocent people;
- Deter identity fraud and identity theft by making it harder for criminals
to use the driver's license as a "breeder document" to perpetrate these
crimes; and
- Strengthen homeland security, by making it more difficult to obtain the
identity documents that enable potential terrorists to disappear into American
society (the driver's license is used to obtain a Social Security card, the
Social Security card is used to obtain a duplicate birth certificate, and so
on and so on).
AAMVA is a state-based, non-profit association representing motor vehicle
agency administrators and senior law enforcement officials in the
US and
Canada. Our members are the recognized
experts who administer the laws governing motor vehicle operation, driver
credentialing, and highway safety enforcement. AAMVA plays an integral role in
the development, deployment and monitoring of both the commercial driver's
license (CDL) and motor carrier safety programs. The Association's members are
responsible for administering these programs at the state and provincial
levels.
Why is driver's license fraud occurring?
Our current licensing structure and the credential that our members issue
were designed for another time and today's system is, at best,
antiquated. The U.S. has more than 240
different, valid forms of passenger car driver's licenses and ID cards in
circulation. Each state and the District of
Columbia has different practices for issuing licenses and reporting
convictions. Individuals looking to undermine the system, whether a
problem drinker, underage drinker, identity thief or terrorist shop around for
licenses in those states with the weakest practices. Unfortunately,
off-the-shelf computer software and hardware is making it easier for individuals
to produce counterfeit licenses and fraudulent breeder documents. In addition,
the lack of standard security features on a license allows individuals to
exploit the system. This makes it difficult for law enforcement to verify
the validity of a license from another state - not to mention the identity of
the person holding it. This situation is worsened by the availability of
counterfeit licenses and fraudulent breeder documents over the Internet and on
the underground market.
Let's look at the vulnerabilities in driver licensing. And more importantly,
the steps needed to tighten the system.
First, individuals can apply for and obtain a license in more than one
state. At this time, DMVs do not have an electronic method to verify
whether a person has been issued a license in another state. We need to
establish an information system that will ensure each driver has only one
driver's license and one driver history record.
Second, the use of false breeder documents to obtain and authenticate a
driver's license or identification card runs rampant within the application
process. DMVs must adopt a uniform resource list for acceptable
identification documents, and they must provide adequate fraudulent document
recognition training to their employees. Furthermore, we must ensure motor
vehicle agencies have the ability, preferably electronically, to verify the
validity of source documents with issuing agencies, such as the Social Security
Administration, Citizenship & Immigration
Services (formerly INS), Services, vital records agencies and other
DMVs.
Third, the driver's license document is easily counterfeited. The
current variety of documents and lack of uniform security features makes it easy
for criminals to alter a real document or create a counterfeit. We must
provide fraudulent document training to not only DMV employees but stakeholders
to thwart acceptance of fake documents. Additionally, motor vehicle
agencies need to adopt minimum, uniform card design and security specifications
for the driver license document.
Fourth, we are all human. For some, this comes with the vulnerability
to criminal behavior, which can result in stolen DMV equipment and inventory and
the acceptance of bribes. We must provide online verification of
the driver license and ID card. We need to implement stronger internal
controls and auditing procedures that detect this behavior and prevent it from
spreading. And, we must implement stiffer penalties and enforcement for
those who choose to break the law.
Fifth, we must protect an individual's personal privacy while trying to bring
the driver's license system into the 21st century. AAMVA has
developed eight principles to address privacy issues in driver license issuance,
and supports the implementation of best practices to ensure the protection and
confidentiality of all personal information contained in the motor vehicle
record.
These problems exist and are interstate in nature. The only way
to ensure that the proper fixes have been applied is for all states to follow
the same roadmap. Inconsistent remedies from state to state will leave
open the loopholes that exist today.
So how do we go about reaching a solution?
Over the course of two years, AAMVA came together with numerous industry
experts to develop a comprehensive solution to enhance the licensing
process. The results of that work are contained in the "AAMVA DL/ID
Security Framework." The emphasis is on the word "comprehensive” -- fixing
one aspect of the problem will not make a difference.
This comprehensive approach addresses:
- Tightened application requirements for obtaining a driver's license,
- Electronic verification of an applicant's driver history and
- Breeder documents,
- Improved processes and procedures for issuance, including internal audits
and training for employees,
- Increased penalties for those who commit fraud, and
- To ensure compliance with these activities, participation by all states in
the Driver License Agreement, a new interstate compact.
During those 24 months, AAMVA and other organizations have addressed these
problems with Congress. In that time, Congress has held four hearings on the
driver's license security issue:
- Senate Committee on Governmental Affairs - April 2002 House Committee on
Transportation and Infrastructure - September 2002
- Senate Committee on Finance - September 2003
- House Select Committee on Homeland Security - October 2003
- The evidence is clear. It's time to stop talking about the
problem and focus on the solution.
- A solution that must be implemented as a comprehensive package and not as
a piecemeal fix.
- A solution that reduces identity theft and enhances homeland security and
highway safety.
- A solution that can protect an individual's personal privacy through
adherence to privacy laws.
- And, a solution that can only be achieved with a state-federal partnership
that includes funding and the political will.
Without a state-federal partnership to implement these changes, this
comprehensive approach is little more than a best practice.
AAMVA is not a regulatory body. Our members implement the laws and policies
of their governors and State legislatures. But they are the technical
experts, and they have done their job by developing a comprehensive solution to
this longstanding problem. Are State legislatures ready to help? The
governors? Congress? Does the political will exist to surmount
privacy and state sovereignty issues and to solve this problem? These are
the key questions today.
Thank you.
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