Financial Institution Data Match Multi-State vs. Single-State Overview
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.
- 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.
There are two differences between the single-state and the multistate matching processes.
- 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.
- SSFIDM - States have the option of offering Method 1 and Method 2; and
- MSFIDM - OCSE offers Method 2 only.