What is FIDM? > Overview > Multi-State vs. Single-State
Background
Under Public
Law 104-193, the Personal Responsibility and Work Opportunity Reconciliation
Act of 1996 (PRWORA), State child support enforcement (IV-D) agencies
must enter into agreements with financial institutions doing business
in the State for the purpose of conducting a data match to identify
accounts of delinquent obligors.
Public Law 105-200,
the Child Support Performance and Incentive Act of 1998, amended PRWORA
to facilitate the data match for multistate financial institutions (i.e.,
those operating in two or more States). This legislation authorizes
the Federal Office of Child Support Enforcement (OCSE) to act as the
conduit between States and territories and the multistate financial
institutions (MSFIs) in the implementation of a centralized data match
process using OCSE's Federal Parent Locator Service (FPLS). Multistate
financial institutions have the option to match through the centralized
FPLS process managed by OCSE or through separate matches with each State
in which they do business.
Thus there is a
two-pronged approach for matching of delinquent obligor cases and financial
accounts:
- the match conducted at the OCSE
level of multistate financial institution accounts against a national
file of delinquent obligors,
- and the match conducted at the State level of State files
of delinquent obligors against accounts of single-state institutions
(i.e., operating in a single state) and multistate institutions declining
the OCSE option.
Similarities
- Goal and Objective: to increase collections of delinquent
child support.
- Participating institutions: banks, credit unions, savings
and loans, benefit associations, insurance companies, safe deposit companies,
money-market mutual funds, and similar institutions.
- Accounts matched: demand deposit accounts, checking accounts
or negotiable withdrawal order accounts, savings accounts, time deposit
accounts, and money-market mutual fund accounts.
- Frequency: matches conducted every quarter; financial
institutions must respond within 45 days.
- Data exchange: data elements supplied by the State child
support agency and reported by the financial institution for Method
1 (all accounts method) and Method 2 (matched accounts method), are
provided in data specifications issued on March 5, 1999 by the Office
of Management and Budget (OMB Control No: 0970-0196).
- Liability: under section 466(a)(17)(C) of the Social
Security Act, financial institutions shall not be liable for disclosure
of information to the State agency; and
- Fees: State law determines whether a State will pay
a fee; fees may not exceed the actual and reasonable costs of conducting
the match; bills for both multistate and in-state matching sent by FI
to State and payment processing performed by State.
Differences
There are two differences between the single-state and the
multistate matching processes.
- Agreement:
- SSFIDM - State enters into agreements with every single-state
financial institution doing business within the State; and
- MSFIDM - State enters into an agreement with OCSE to act as its
agent, and OCSE enters into agreements with every multistate financial
institution electing to match through the FPLS.
- Match Method:
- SSFIDM - States have the option of offering Method 1 and Method
2; and
- MSFIDM - OCSE offers Method 2 only.