Death

Nikada/iStockphoto
24 FRAUDMAGAZINE
Fraud
www.fraud-magazine.com
 This
It might be impossible to eradicate this pervasive
fraud, but cross-referencing documents with the U.S.
Social Security Administration’s Death Master File

Identity
might be the key to significantly reducing the
success rates of perpetrators.

“Grandma! What big sunglasses you have!” In the fuzzy

Theft
photo below, taken with a security camera at a department of motor
vehicles’ office in New York City, the elderly woman is actually a man
impersonating his deceased mother. Thomas Parkin (shown in a wig and big
sunglasses) defrauded the U.S. government out of more than $100,000 by

is Alive
stealing his mother’s identity after she died. Parkin’s accomplice, the man to
the right in the photo, posed as a helpful nephew.
Parkin committed the fraud by giving his mother’s funeral home an
incorrect date of birth and Social Security number (SSN) for her and then
using the actual identification numbers to steal her monthly $700 Social

and
Security benefits and rent subsidies.1
Death can be big business for fraudsters. Imagine the societal conse-
quences if theft of decedents’ identities becomes mainstream. A caregiver,
entrusted with financial oversight for an ailing loved one or client, could ob-
tain and use that person’s identification for illicit purposes. Or a physician

Kicking
could use a deceased physician’s SSN and then bill insurance companies for
services never rendered to the decedent’s former patients.
These actual cases, playing out across the globe, often remain under the
radar until it’s too late and damage has been done. Using a decedent’s SSN
is really nothing more than an emerging form of identity theft.

By Cheryl B. Hyder, CFE, MT, CPA, CVA, CFF,

and Christine L. Warner

September/October 2010 FRAUDMAGAZINE 25

DEATH FRAUD

In this article, we’ll: the security and confidentiality of personal information held at
• Describe identity theft in its native forms the institution. In addition, the GLB act “… prohibits ‘pretex-
• Explain the concept of death fraud and introduce the Social ting,’ the use of false pretenses, including fraudulent statements
Security Administration’s (SSA) Death Master File (DMF) and impersonation, to obtain consumers’ personal financial
• Explore the evolution of death fraud information, such as bank balances.”4
• Propose proactive measures to employ in your practice and to • The Identity Theft Penalty Enhancement Act of 2004 added two
suggest to your clients for their protection years to the identity theft perpetrator’s prison sentence, and five
years if the crime involved terrorist activities.
DEFINING IDENTITY FRAUD
You’re probably aware of identity theft, but you might not be DEATH FRAUD
aware that effective Nov. 1, 2008, the U.S. Federal Trade Com- Death fraud, at its roots, is simply a new spin on an old scam. As
mission (FTC) and several other federal agencies now require we continue to discover and enjoy technological advances, person-
financial institutions and creditors to have identity theft pre- al data theft will only become more prevalent. And identity theft
vention programs in place to help prevent, detect, and mitigate against folks who are unable to speak for themselves threatens to
identity theft occurrences – primarily when the accounts are increase in such a data-driven environment.
opened but also for the duration.2 This is just one reason why There are two common strategies to illegally obtain personal
understanding identity theft risk involving decedents is more information, each of which presents its own problems. In the first
critical than ever. scenario, a trusted friend or loved one gains access to another’s
Identity theft, in broad terms, is the unauthorized and illicit SSN. In the second scenario, which is growing in popularity, the
use of another person’s personal identification information – typi- perpetrator obtains a decedent’s SSN from discarded documents,
cally an SSN or driver’s license – for the impostor’s personal gain. databases, health claim files, or even the SSA’s Death Master File
In the United States, it’s unlawful for any person to: (DMF). The DMF is a central database that contains more than
1) Knowingly and without lawful authority produce an identifica- 84 million records on deceased U.S. citizens. Each entry includes
tion document, authentication feature, or a false identification the person’s SSN, full name, date of birth, date of death, and
document city/state.
2) Knowingly transfer an identification document, authentication Because decedents obviously aren’t able to detect or pro-
feature, or a false identification document knowing that such docu- test the unauthorized use of their identification credentials, the
ment or feature was stolen or produced without lawful authority responsibility falls to their executors, surviving family members,
3) Knowingly possess with intent to use unlawfully or transfer or other interested parties, if there are any. Anti-fraud profession-
unlawfully five or more identification documents (other than als should help the general public understand that vigilance over
those issued lawfully for the use of the possessor), authentication one’s identity doesn’t end when a person enters into a guardian-
features, or false identification documents ship arrangement or even with one’s last breath.
4) Knowingly possess an identification document (other than Fraudsters have long known about stealing the identities
one issued lawfully for the use of the possessor), authentication of deceased or incompetent individuals to commit fraud. What
feature, or a false identification document with the intent for such makes this topic hotter than ever is that data can be sold and dis-
document or feature be used to defraud the United States3 tributed quickly, and SSNs of the dead are more readily available
The third and fourth prongs give the law teeth in that unau- than SSNs of the living (and absent the use of the DMF or similar
thorized possession of another person’s identifying information, tool, they are less likely to be detected). Collecting payments
or fraudulent information, with intent to either use it personally intended for the dead or in the name of the deceased is big business
or to transfer it to another party for unlawful purposes (includ- that touches several sectors of the economy including health care,
ing intent to defraud the United States) is a crime. While this life insurance, investments, retirement benefits, and others.
language gives prosecutors additional tools to obtain a conviction, Among the incarnations of death fraud, Social Security fraud
they also must prove one’s intent, which is never as clear as it – using a deceased person’s SSN to obtain their Social Security ben-
might seem. efits – will be examined first, after we address in detail the DMF.
Keep in mind that identity theft and its attendant risk can’t
realistically be legislated out of existence, but it’s an exposure that DEATH MASTER FILE
can, with regulatory support, be managed. In the past 12 years The SSA created the DMF in 1980 following a private citizen’s
we’ve seen many legislative deterrents to identity theft including: lawsuit via the Freedom of Information Act.5 The database’s
• The Identity Theft and Assumption Deterrence Act, which was ef- purpose is to help prevent payments of SSA benefits to deceased
fective Oct. 30, 1998. It makes identity theft a federal crime with parties. For a fee, users can either search individual names online
penalties up to 15 years of imprisonment and a maximum fine of at www.ssdmf.com, or they can purchase the entire database
$250,000. and run their queries. The SSA maintains this comprehensive
• The Gramm Leach Bliley (GLB) Act of 1999 makes it manda- database in conjunction with the National Technical Information
tory for any financial institution to assign one person to safeguard Service branch of the Department of Commerce (www.ntis.gov/

26 FRAUDMAGAZINE www.fraud-magazine.com
 DEATH FRAUD

products/ssa-dmf.aspx). The SSA keeps the database current by PREVENTING AND

purchasing death certificate information from state governments DETECTING DEATH FRAUD
and gathering death notifications from funeral homes and friends
The Death Master File (DMF) (www.ssdmf.com), used in com-
and family of the deceased.
Here’s the catch: The DMF is both an anti-fraud weapon bination with traditional accounts payable tools to prevent and
and a point of vulnerability. Current legislation – including the detect fraud, provides another tool for the anti-fraud tool belt. We
USA PATRIOT Act of 2001 and the FTC’s mandate to imple- suggest that an accounts payable or procurement department
ment identity theft prevention programs – has made the DMF enhance its fraud mitigation efforts at various points of the pay-
an invaluable fraud-fighting tool. The PATRIOT Act made it ment cycle by:
mandatory for government entities to ensure their customers
weren’t on terrorist watch lists, which made identity verification a
hallmark in the fight against terrorism. It remains to be seen how 1. Prior to engaging the vendor or prior to issuing payment:
the FTC’s mandate will be incorporated into businesses, but one • Validate vendors before doing business with them; consider
anticipated effect is that DMF usage will be incorporated into comparing the taxpayer identification numbers on the W-9s
companies’ anti-fraud programs. However, in the wrong hands, against the DMF.
the DMF could be used for illicit purposes. • Cross-reference personal identifiers contained in document sub-
How should you use the DMF to fight fraud? First, you need
missions against the DMF. If these identifiers aren’t in the DMF,
to know how to mine the data for usable information. The DMF
is an immense “batch” file that doesn’t accommodate data trans- the inference is that the person in the documents is living and
fers into off-the-shelf spreadsheet or database analysis programs breathing. Of course, this presupposes that the DMF is current
such as Microsoft Excel or Microsoft Access. If you purchase and accurate. Anomalies discovered at this stage are capable of
access to the 84-plus million records, you need to be able to being resolved before payments are issued. State jurisdictions are
manipulate the data. Analysts who cross-reference this file on a beginning to embrace this strategy to reduce their risk of becom-
daily basis use large databases, such as SAS or Oracle, to crunch
ing a victim of death fraud.1
the numbers. However, the DMF is a powerful tool in the fight
against fraud because you can use it to prevent or retroactively
uncover manifestations of death fraud. 2. As part of claim submission process (before payment is issued):
Compare information contained in submitted applications for
MANIFESTATIONS OF DEATH FRAUD payment (i.e., life insurance, tax refunds, etc.) against the DMF.
Social Security Fraud Corporations and government entities might uncover a fraudulent
In a macabre case of Social Security fraud out of Florida, a
submission rooted in use of a decedent’s SSN.
woman named Penelope Jordan hid her dead mother’s body in a
back room of their home for six years while she collected $40,000
annually in Social Security benefits intended for her mother. 3. Periodically and at routine intervals, “scrub” data in payment files:
Surviving and former spouses of a decedent are entitled to • Search for duplicate SSNs or current payee SSNs appearing in
survivor benefits if the deceased was receiving Social Security the DMF.
benefits. Widow(er)s of deceased Social Security beneficiaries are • Cross-reference vendor and employee files against the DMF
eligible to receive either the deceased’s Social Security payouts or
and identify suspect transactions that might include payments to
their own payouts – whichever amount is greater. Jordan clearly
violated the law by failing to report her mother’s death to the deceased individuals.
SSA, which would have resulted in benefit cessation. She was • Identify vendors and employees sharing SSNs, addresses, bank
prosecuted under 42 U.S.C. § 408(a)(1)-(8), which sets forth accounts, or telephone numbers, and employees who aren’t using
penalties for felony fraud violations under Title II of the Social their annual vacation or sick leaves.
Security Act.
The SSA’s first line of defense to prevent such schemes
4. Health-care providers, insurers, and government agencies
might be to cross-reference all outgoing benefit payments with the
DFM. A second line of defense might be to retroactively compare should also cross-reference provider payees against the DMF
Social Security payments after an individual’s date of death and to identify services provided or payments issued in which the
pursue recoveries. Employing preventive measures, of course, relevant date is after the individual’s date of death. In health care
would save time involved in chasing recoveries on the back end. matters, determine if patients were alive at the stated time of
This also minimizes the overall cost of potential fraud. service and confirm that the physician was also alive at the time.
Social Security benefits that are handled by representative
1
“Audit of Selected States’ Medicaid Payments for Services Claimed to Have Been
DEATH FRAUD continued on page 44 Provided to Deceased Beneficiaries.” Sept. 26, 2006.

September/October 2010 FRAUDMAGAZINE 27

DEATH FRAUD

continued from page 27

payees (rep payees) are particularly vulnerable to fraud, waste, and • Publicly available records on the Internet including:
abuse. Rep payees are typically benefit recipients’ friends or family º http://govdeathrecords.com
members who collect benefit payments on behalf of individu- º www.ssdmf.com
als unable to manage their financial affairs for various reasons. º www.rootsweb.com7
When family or friends can’t assume this role, others – usually • Access to electronic information via computer hacking, spy-
professional conservators – serve as the rep payees for these ware, and similar means
beneficiaries. It’s easy to see how fraud can occur under these To help prevent tax refund frauds, we suggest that payor
circumstances. agencies cross-reference the payee name and SSN with the DMF
Tax Refund Fraud: Part I and withhold payments intended for deceased persons until
In 2007, a large local government tax refund fraud was exposed in anomalies are fully resolved.
Washington, D.C. Harriette Walters, the former manager of tax Accounting Fraud
refunds for the District of Columbia, bilked the D.C. government Death fraud can occur many ways within an accounting depart-
out of an estimated $48 million in fraudulent tax refunds over 20 ment – most commonly via disbursement fraud. One strategy is
years. The fraudulent tax refund checks were deposited into sham to combine a decedent’s SSN with a new and fictitious vendor.
corporate accounts controlled by Walters’ relatives, or they were Another disbursement method is to change the mailing address
issued to deceased taxpayers and then redirected into accounts for a deceased employee or vendor to a post office box or mail
controlled by co-conspirators.6 drop that the fraudster controls.
Legitimate checks intended for a A recent case of criminal tax fraud
deceased person were returned to the gov- The Washington Post clearly demonstrates a real concern – cre-
ernment via the U.S. Postal Service, then ation of new businesses using a decedent’s
altered and cashed. The Washington Post counted 92 distinct identification information to conceal the
counted 92 distinct fictitious corporations entities’ ownership. Georgette Richie and
that were set up to receive the fraudulent fictitious corporations her husband, Phillip Richie, created Web-
refunds including companies like “Bilke- ster General Inc. and Geo Tech Systems
mor LLC.” While we do know that Walters that were set up to Inc., both of which did business with
used decedents’ SSNs for certain phases of AMPORTS Inc.
her scheme, the extent of death fraud com- receive the Phillip, however, was also director of
mitted overall remains unknown. engineering at AMPORTS and responsible
To prevent this fraud, the District of fraudulent refunds for awarding contracts to vendors and
Columbia Comptroller’s Office could have approving payment of their invoices. He
cross-referenced its tax records against the including companies circumvented this apparent conflict of in-
DMF. The office could have made further terest by creating the two companies, which
inquiries when companies or individuals like “Bilkemor LLC.” resulted in $12 million in contract pay-
had nonphysical addresses. ments to the companies from AMPORTS
The Walters’ case is atypical. It’s more and in turn netted $4 million to the Rich-
common to generate phony income tax refunds. ies. Georgette also used Internet banks to open accounts so the
Tax Refund Fraud: Part II purported president of the companies wouldn’t have to appear
Recent cases in California and New Jersey illustrate how easily de- in person.
cedent information can be used to generate inappropriate income This case amplifies the need to cross-reference vendor and
tax refunds – absent some method of cross-reference with DMF or employee data files against the DMF. Even with the tightest of in-
another similar database. In California, two men took advantage ternal controls, a rogue employee can create a fictitious employee
of this process gap and applied for $2 million in false tax refunds. or vendor using a decedent’s personal information to create, at
In New Jersey, a woman submitted false tax returns on behalf of a minimum, a bank account and a mailing address within the
28 deceased individuals, expecting a refund of $108,000. fraudster’s control. In this particular case, they also further con-
You might ask: How did these perpetrators acquire the dece- cealed their intent by creating fictitious entities.8
dent SSNs? In California, the fraudsters obtained SSNs through a Health-care Fraud
Certified Public Accountant and Internet research. Other, but by Health-care fraud is a highly complex and specialized area of fraud
no means all-inclusive, ways to obtain SSNs of deceased persons examination because of the number of players and volume of
include: transactions involved: physicians, hospitals, equipment suppliers
• “Dumpster diving” at a decedent’s residence after reading the and manufacturers, pharmacies, patients, medical-billing special-
victim’s obituary ists, and third-party administrators. Each of the players have
• Access through friends and family their specific transactions and potential to commit fraud against

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DEATH FRAUD

another segment of the health-care industry – a governmental necessarily easy. The Centers for Medicare and Medicaid Services
agency that’s subsidizing the underlying care or the care recipient. (CMS), for instance, has the inherent ability to retroactively (or
Health-care fraud is big business, as is fighting health-care proactively) cross-reference physician files with the DMF, discover
fraud. The National Health Care Anti-Fraud Association recently payments made to deceased physicians, and attempt to recover
estimated that approximately 3 percent of all U.S. health-care associated payments. This is time consuming in either case, and it
spending – or $68 billion annually – is lost to fraud.9 might complicate things to proactively withhold payment or deny
There are several ways to commit health-care fraud by using a claim, but it would also slow the pace of the fraud loss.
a decedent’s identifying information. Some of the more common CMS’ electronic Medicare Prospective Payment System al-
include: ready has electronic safeguards in place to either deny or approve
• Services purportedly rendered by a deceased provider and a claim based on its characteristics. We don’t believe that adding
billed to an insurer an automated cross-reference to the DMF (a data set containing
• Services purportedly rendered to a deceased patient and billed 84 million-plus records) is a practical solution to the health-care
to an insurer fraud loss dilemma; instead, we believe a data query this large
• Purchases of durable medical equipment purportedly made might slow the claim approval process to a crawl.
on behalf of a decedent (and billed by the physician using that A viable alternative might be adding a field/column titled
person’s identifying information) “doctor date of death” to the CMS’ National Provider Identifier
Deceased Providers Health insurers are becoming in- database and cross-referencing this data to the DMF periodically
creasingly proactive in their fight against in an automated query that generates
health-care fraud. Insurers and analysts run exceptions in a timely manner. This would
hundreds of algorithms to analyze huge Typically, no enable CMS to validate claims against its
volumes of data to identify possible health- National Provider file, which at 800,000
care fraud, waste, and abuse. proactive process is files, is substantially smaller than the DMF.
One of insurers’ typical practices is to Assuming the National Provider file con-
run an analysis to detect payments made in place to detect tains current death information for each
for services rendered after the date of a physician, this procedure would enable
physician’s death. This sort of scheme is submitted claims with CMS to identify decedent physicians in
generally undertaken by an insider – usu- a timely manner and deny claims associ-
ally a practitioner in the same medical a service date after ated with them. Insurers could use similar
practice as the decedent or a third-party protocols.
administrator who provides medical-billing the patient date Deceased Patients Fraud schemes
services for that physician. In these cases,
the fraudster – with access to the practi-
of death. that involve submitting false claims to
insurers for services allegedly rendered to
tioner’s SSN and mailing information – is deceased patients appear to be on the rise.
able to control both the reimbursement submission and the col- As with all of the scams discussed in this article, fraud examiners
lection. Government and private industry analysts can cross-refer must be cognizant of the logical possibility that an input error
provider submissions against the DMF so they can identify these is behind the detected anomaly – possibly the purported service
inappropriate payments and conduct recovery actions. date, date of death, or even the DMF.
In July 2008, the U.S. Senate Permanent Subcommittee on Typically, no proactive process is in place to detect submitted
Investigations held a hearing to examine claims made to Medicare claims with a service date after the patient date of death. CMS
for durable medical equipment that contained identification and private insurers currently are able to retroactively identify pay-
numbers of physicians who died at least one year prior to the al- ments made for services rendered after the patient date of death,
leged date of service.10 According to the subcommittee’s findings, typically using one of two methods: 1) compare the service date
Medicare overpaid an estimated $60 million to $92 million to on the patient claim form to the patient’s death date, and flag the
these deceased doctors during the period of 2000 through 2007. claim if the service date is after the date of death and 2) cross-
Had the study included the most recent 12 months follow- reference the patient eligibility file (which contains the SSN) with
ing the physicians’ deaths, it’s estimated that the fraud loss would the DMF to determine the accurate date of patient death, and
have increased to more than $100 million. This is a conserva- then compare service date and death date.
tive estimate because the subcommittee’s analysis only included This type of fraud has plagued state Medicaid agencies and
alleged dates of service more than one year after the physicians’ CMS for years. The Health and Human Services Office of the
dates of death. In some cases, the doctors had been dead for more Inspector General estimated in 2006 that $27.3 million was paid
than 10 years. This further illustrates the need to analyze not only to providers on claims dated subsequent to the dates of patients’
patient claim records but also physician files. deaths.11 That $27.3 million, based on eight out of the 10 audit
Preventing this type of fraud is straightforward, but not states, was extrapolated. However, the enormity of the inspector

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general’s estimate strongly suggests that death fraud – specifically mit. While it can’t be totally prevented and not all cases can be
billing for services to deceased individuals – needs to be on the detected, leveraging the DMF as a resource will certainly enable
radar. organizations to minimize their risk of falling prey to an orches-
Although the concept is simple, getting the DMF death dates trated death-fraud scheme.
to line up exactly with other sources of death dates, such as state
eligibility files and Bureau of Vital Statistics files, continues to
present a challenge. Cheryl B. Hyder, CFE, MT, CPA, CVA, CFF, is the principal
Stark Law Violations The Stark Law (42 U.S.C. 1395), at Hyder Consulting Group, a litigation consulting firm based in
named after Rep. Fortney “Pete” Stark (D-CA), prohibits a physi- Alexandria, Va. She’s the president of the ACFE’s Metropolitan-DC
cian from referring patients to a practice in which the provider Chapter and holds leadership positions in other professional organi-
has a financial interest. Individual Stark Law violations (i.e., each zations. Hyder has been designated as an expert witness in matters
claim or referral) are subject to financial penalties, which are sig- involving forensic accounting, financial fraud investigations, ac-
nificantly increased if it’s determined that the physician engaged counting malpractice and standard of care, commercial damages, and
in conduct to conceal the relationship. With this perspective, con- business valuation. Her e-mail address is: [email protected].
sider the increased risk of using a decedent’s personal informa-
tion to obfuscate the true ownership of a practice and the Stark Christine Warner is a director of quality assurance for Thomson
noncompliance. Consider the consequences if a physician or Reuters, at which she conducts Medicaid fraud detection analyses
physician’s practice created a referral practice using a decedent’s using SAS software. Her e-mail address is: [email protected].
SSN to mask ownership interest in that referral entity.

TOOLS TO PREVENT DEATH FRAUD

The principal tool to reduce or eliminate instances of death 1
Millman, Jennifer. “Man Poses as Dead Mom To Collect Benefits.”
fraud risk is the DMF. Cross-walking financial databases within NBCNewYork.com. June 17, 2009. www.nbcnewyork.com/news/local/
an organization – tax refund files, health-care claims files, ven- Man-Poses-as-Dead-Mom-to-Collect-Benefits.html.
dor or contract files, and accounting records – against the DMF 2
Federal Register. Vol. 72, No. 217. Friday, Nov. 9, 2007. Rules and regula-
will identify payments intended for or attributed to deceased tions available online at:www.ftc.gov/os/fedreg/2007/november/
individuals. These payments might be mistakes, possibly at- 071109redflags.pdf. The rules implementing section 114 of the Fair and
tributed to sloppy data management. They might be legitimate. Accurate Credit Transactions Act (FACT Act) require each financial
Or they might indicate fraud. In every case, however, excep- institution or creditor to develop and implement a written identity theft
tions should be flagged and potentially inappropriate payments prevention program to detect, prevent, and mitigate identity theft in con-
investigated. nection with certain new or existing accounts.
The second tool in your toolbox should be data-mining 3
18 U.S.C. § 1028, Ch. 47: Fraud and related activity in connection with
capability. If you don’t have SSNs in your database, program- identification documents, authentication features, and information.
mers should be able to use other data fields common to both Eight activities identified in the statute; we listed the most relevant here.
database sets to identify suspect payments. In addition, the data 4
“The Gramm-Leach Bliley Act.” www.ftc.gov/privacy/privacyinitiatives/
miner can look for changes in bank account routing informa- glbact.html.
tion, payee addresses, and other information on a broad scale. 5
Ways and Means Social Security Subcommittee. Committee on Finan-
In the opening example, if Grandma’s Social Security check cial Services Subcommittee on Oversight and Investigations. Nov. 8,
was suddenly routed to a new or different bank account, this in- 2001. www.ssa.gov/legislation/testimony_110801.html.
formation would stand out and alternative explanations would 6
www.dcwatch.com/govern/cfo071107b.htm and Harry Jaffe, “Godfather
have been explored. of DC Tax Scam Still At Large.” The Examiner. Sept. 19, 2008.
The third tool in your toolbox is a qualified and competent 7
A search on this website for “Jane Smith” revealed more than 1,000 hits
financial investigator or field auditor. No matter the indus- from the Social Security Death Index (not to be confused with the Death
try, potentially fraudulent overpayments must be investigated Master File), each of which provides a Social Security number in addition
beyond a data report if recovery of these amounts is an objective to other personal identifying elements.
of the analysis. The information provided by the data miner by 8
www.irs.gov/compliance/enforcement/article/0,,id=187277,00.html.
itself might provide the predication required to instigate a fraud 9
www.nhcaa.org/eweb/DynamicPage.aspx?webcode=anti_fraud_
examination and spring-board the investigation. This same resource_centr&wpscode=TheProblemOfHCFraud
information will provide the basis for leads in the investigation 10
http://hsgac.senate.gov/public.
as well. 11
“Audit of Selected States’ Medicaid Payments for Services Claimed to
Identity theft, as it relates to death fraud, is big business for Have Been Provided to Deceased Beneficiaries.” http://oig.hhs.gov/oas/
fraudsters and the plethora of personal-identifying information reports/region5/50505530.pdf. Sept. 26, 2006.
available on the Internet makes identity theft easier to com-

September/October 2010 FRAUDMAGAZINE 47