There is no compelling reason to change the current form. It is quite clear and easy to use as it stands. And the regulations for filling-in the form and handling the form after the applicant’s submission seem appropriate, reasonable and consistent with Virginia law.

Further, the proposed revisions are far from minor form changes to improve handling efficiency. The proposed changes, though subtle, would seriously undermine the integrity of the Election Process.  Accordingly, I urge that these proposed revisions be rejected out-of-hand.

Following are some examples to support this position. They are not intended to be exhaustive.

Please note the following items under Section “B” of the handling instructions

The section begins

“The following omissions are not material and a voter registration application may not be denied for failure to include one or more of the following:”

Item nine (9) is one of the condition statements that follows and reads,

“9. Social security number if the applicant writes “None” in Box 1”

This is a very big problem. This would mean that registration could not be denied to someone who does not enter a valid SSN, as long as they indicate “None” on the form.

The term of the proposed language is mistaken and incorrect. The SSN is certainly “material”. It is essential. The SSN is required by Virginia Law, § 24.2-418, which requires a SSN without exception or substitute.

There is some excellent rationale to support this. SSNs are an essential component to our identity as citizens in the United States. And on a Voter Registration form, which relies heavily upon the right-person-identity, this is a very reasonable requirement. Further, allowing someone to submit such an application without an SSN and simply entering “None” in its place, would actually facilitate at least two different crimes. The first would be to allow unqualified non-citizens to apply and receive a voter registration. The second crime would be the establishment of a false identity. That is, the applicant could have a valid SSN under a different name, but in this case, apply with an alias and claim they have no SSN.

Both of these crimes would lead to the creation of fraudulent registrations because, under the current proposed revision to the rules, this person’s application would be required to be processed as valid and a registration issued. Interestingly, the SBE and other authorizing officials involved could very well be considered complicit in the commission of these crimes.

Requiring valid SSNs are an excellent first step protection against such fraud.

Accordingly, the requirement for a valid SSN should be retained as a showstopper. If there is no valid SSN, there should be no Voter Registration issued.

Likewise, with items 8 (Gender),11 (US Citizenship) ,12 (Felon) & 13 (mental incompetence). All of these are required by law and should continue to be required in the application.

While there is a signatory statement at the end of the document that does touch on items 11, 12 & 13, the larger purpose there is to obtain a signed acknowledgment of the penalty for the crime.  It basically indicates that they understand the punishment if they are caught.

The check boxes, however, serve to underscore, emphasize and make clear that the applicant is testifying that these statements are true in their application. It helps to further document that if a person falsifies this important document, they are doing so in full knowledge of their crime. And even if these checkboxes are considered redundant by some, it is good redundancy to have to assure there is no misunderstanding about such important aspects of this application. This can be especially helpful for those who are challenged by the written English language.

Accordingly, as with item 9, the SSN, these checkboxes should remain as showstoppers and no Voter Registration should be issued without them being appropriately checked.

The form revisions as proposed should not be adopted.

Sincerely, Roland Smith