DCL-00-52, Multistate Financial Institution Data Match and Insurance Companies

DCL-00-52 MAY 8, 2000

TO: ALL STATE IV-D DIRECTORS

RE: Multistate Financial Institution Data Match and Insurance Companies

Dear Colleague:

Attached is a copy of an article published by the American Council of Life Insurance to its membership. It outlines the basic requirements of financial institution data match (FIDM) and the operation of the multistate FIDM program.

With the passage of the Financial Services Modernization Act of 1999, Congress allowed more freedom for insurance companies to affiliate with other types of financial institutions. As a result, questions have arisen regarding the obligations of insurance companies to participate in the FIDM program. As the article points out, insurance companies are included within the statutory definition of "financial institution" for purposes of FIDM. However, only products which would meet the statutory definition of account are reportable, regardless of an affiliation between an insurance company and a more traditional financial institution. Accounts that are required by section 466(a)(17)(D)(ii) to be included in FIDM are demand deposit accounts, checking or negotiable withdrawal order accounts, savings accounts, time deposit accounts, and money market mutual fund accounts. States must require that the listed accounts, at a minimum, are reportable; however, they may expand the definition of account. It is important to note that traditional insurance products, such as annuities and whole life policies, are not specifically included in the definition of account under the Federal law and are not now subject to the MSFIDM data match, though they may be reportable to a particular State under its own statute.

If you have any questions regarding Multistate FIDM, please contact Ann Barkley at 202-260-4697. If you have any questions regarding Instate FIDM programs, please contact Gina Barbaro at 202-401-5426.

Sincerely,

David Gray Ross
Commissioner
Office of Child Support Enforcement

Enclosure

cc: State MSFIDM Liaisons
Regional Program Managers
ACF Regional Administrators

ACLI: General Bulletin (Adobe PDF)