Are there additional elements that the Commission should add to the definition of the term “identity theft”?
No. Added elements would reduce the inclusiveness, and hence the flexibility, of this important definition. B. Questions relating to the definition of identity theft report B.1. Does the term “identity theft report” as defined by the Act need further definition? Yes, this definition must be fundamentally changed, as described below. First, a few technical suggestions. The word “reasonably” should be added to section 603.3(a)(1), before “provide,” and the phrase “to the extent requested on the report form and known to the consumer at the time the report is filed.” A report should not be deemed insufficient if it gives all of the information requested by the report form which was reasonably available to the consumer at the time the report was filed. Similarly, section 603.3(b) should be expressly qualified by adding “to the extent known to the consumer at the time the report is filed” after “as follows.” Finally, section 603.3(b)(4) should refer to “Other reasonable” information rather t
