FN37.  The Department of Homeland Security’s own Privacy and Integrity Advisory Committee, in a February 2009 letter to DHS Secretary Janet Napolitano, noted significant concerns with regard to privacy and fraud and recommended that the program not be expanded until these concerns are addressed: “The Committee recommends that DHS eliminate or significantly reduce fraud vulnerabilities in the current E-Verify system.  At a minimum, such reductions should occur before further expanding the mandated use of the system . . . The lack of procedures for authenticating the eligibility of employers to use the system creates a significant opportunity for fraud, which could result in legal residents and citizens becoming victims of identity theft.”  Draft Letter from DHS Data Privacy and Integrity Advisory Committee to Secretary Janet Napolitano and Acting Chief Privacy Officer John W. Kropf (Feb. 2, 2009), AILA InfoNet Doc. No. 09020362 (last visited March 10, 2009).