mr. speaker , i am submitting for the record the following remarks from mr. arkadi kuhlmann , ceo of ing direct , in opposition to the bankruptcy reform legislation under consideration .  i remain a strong supporter of s. 256 ; however , i believe mr. kuhlmann 's statement should be made part of the record .  statement of arkadi kuhlmann , ceo , ing direct mr. speaker , i am arkadi kuhlmann , ceo of ing direct , a federally chartered thrift headquartered in wilmington , delaware .  ing direct launched in the u.s. in september 2000 to challenge traditional banking by touting the high interest , no fee and no minimum orange savings account as its signature product , with a brand vision to lead americans back to saving .  ing direct has since expanded its product line to include the orange mortgage , the orange home equity line of credit , orange cds and the orange investment account .  with over 2.5 million customers and more than $ 43 billion in assets , ing direct is the fourth largest thrift in the u.s. the house is now considering consumer bankruptcy legislation that would make major changes to how consumers ' debts and obligations are treated in the bankruptcy process .  thank you for this opportunity to submit testimony for the record on this legislation .  despite the many important and positive changes this bill would make to our bankruptcy laws , this proposal remains seriously flawed .  one significant oversight is the bill 's failure to consider one of the biggest problems we face in business today : identity theft .  the washington post ran a story recently about a woman whose identity was stolen , yet her credit card company forced the fraudster 's debt on her by using the arbitration clause in her card agreement .  the bankruptcy bill must address the possibility that identity theft could lead to financial devastation through no fault of the person 's own .  in addition to overlooking the problem of identity theft , this proposal had additional shortcomings .  it actually encourages further bad lending decisions by removing an important market discipline -- the possibility of a clean bankruptcy .  without important changes , millions of consumers , who might otherwise be savers , will be encouraged into debt by aggressive credit card and other lending .  we believe it is crucial that a serious study of the connection between credit card marketing and personal bankruptcy be completed .  the bill as drafted requires such a study .  we challenge the congress to take a very hard look at the results of the study and consider further legislation , if necessary .  another important issue is the bill 's creation of a `` means test. '' by giving disparate treatment to secured versus unsecured debt , the law would treat secured creditors even more favorably than under current rules .  we believe the means test should be applied across the board or not at all .  we at ing direct believe this country is still willing to give working americans -- the engine of our economy -- a second chance when debt overwhelms them .  this bill seriously limits that second chance .  thank you for the opportunity to present our views .  