Social Security is requesting comments on how it applies the prohibition on people who have been convicted of certain crimes serving as representative payees. Applying this isn't as simple as one might think. Quite a number of people who need a representative payee have no one willing to be their representative payee who doesn't have a criminal history. There are many people who have criminal histories who make fine representative payees. I can think of one old client of mine who killed an abusive husband who would make a fine representative payee. These issues only seem simple when seen from a distance. Up close, everything looks complicated.