As an experience Virginia registrar, I agree with most of the other comments submitted by my colleauges and urge the SBE to NOT adopt the proposed changes. While they may be well intended, these changes have not been well thought out, have not been properlly vetted by professionals (good suggestions that came out of a previous workgroup consisting of registrars were ignored), and will cause all kinds of problems for the process and the integity of our system.

1. Do not invite applicants to enter NONE for SSN. Many who do not wish to reveal this information will do so, and we have no way of verifying the information. In my 20+ years in Arlington, I have only encountered one new applicant who claimed he did not have a SSN. I understand the concerns of some applicants, especially in light of recent federal government breaches. A better idea might be to thoroughly explore implications of switching to SSN-4 instead of the full number. (I know many of my colleagues don't like that idea, but it may well be coming anyway.)

2. Require applicants to properly answer the check boxes. Saying the information is required but then saying it isn't a material omission sends a mixed message. 

3. Keep the previous registration information at either the top or bottom of the form, and keep the required information part of the form at an 8x5 size that will fit in most offices' files. I hear what ELECT has said about the ability of scanning and capturing previous registration information electronically, and while my office welcomes these advances, not every registrar has the means and resources to do so. There may also be some legal and/or records retention changes necessary before we adopt these changes on a large scale. For the short term, it is business as usual.

There is real concern that, if these regulations/changes are adopted, that the ability of professional registrars to validate information provided will be severly compromised. If ELECT/SBE wants to make the process easier for applicants there are other, better ways - namely, fully integrate voter registration with the DMV process, since DMV applications are by far the largest source of incomplete applications. If applicants at the DMV were required to electronically answer required questions before submitting the application, the number of denials for missing info would be reduced dramatically. We've already seen this with online registration, where information is required. DMV integration is a logical step.

But please do not implement these changes.

Linda Lindberg, Director of Elections, Arlington County