What is the Financial Institution Data Match (FIDM)?
State Child Support programs must enter into agreements with financial institutions to conduct data matches to identify accounts of delinquent child support obligors.
The Financial Institution Data Match (FIDM) program stems from Public Law 104-193, Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), passed in 1996. Additional legislation in 1998 simplified the process for multistate financial institutions doing business in more than one state. Public Law 105-200, Child Support Performance and Incentive Act of 1998, modified PRWORA to facilitate the data match for multistate financial institutions. Although the procedures for data match with single-state and multistate financial institutions differ, the requirements are identical. This data match requires state child support agencies to enter into agreements with financial institutions and to automate to the greatest extent possible.
With passage of Public Law 105-200, the Federal Office of Child Support Enforcement uses its national file of delinquent obligors for the data match with multistate financial institutions and transfers matched data to State agencies.
What is Common to Single-State & Multistate Matching?
- Types of institutions & accounts subject to the match
- How often the match is conducted
- Data specifications
- Liability protections
- Fee responsibilities
- Federal Lien/Levy provisions
The Goal of FIDM
To increase collections of delinquent child support.
Financial Institutions that Must Participate in FIDM
- Banks, savings & loans
- Federal & State Credit Unions
- Benefit associations, insurance companies, safe deposit companies, money market mutual funds
Type of Accounts Subject to the Data Match Program
- Demand Deposit Accounts
- Checking Accounts
- Savings Accounts
- Time Deposit Accounts
- Money Market Mutual Fund Accounts
Frequency of the Data Match
Matches must be conducted each calendar quarter.
Data That Must Be Returned to the Child Support Program
- Record Address
- Social Security Number
- Taxpayer Identification Number
- Other Identifying Information
- Section 466(a)(17)(C) of Social Security Act - Financial Institutions not liable for disclosure of information or surrendering of assets to the State IV-D agency.
- Section 469A(a) - Financial Institutions not liable under any State or Federal law for disclosing information to the FPLS.
- State law determines whether a State will pay a fee or not.
- The fees must not exceed the actual costs of conducting the match.
- Federal Financial Participation is available for "reasonable" match costs.
Lien and Levy of Financial Accounts
Under Section 368 of Public Law 104-193 (PRWORA), a lien arises by operation of law, so that a lien is automatically created as soon as child support becomes past due.
- A legal claim against someone’s real or personal property as security against a debt or obligation.
- Impedes the debtor’s ability to use or transfer the property.
- An actual collection or seizure of the property.
- With regard to FIDM, a levy is the actual taking of the financial asset to satisfy the debt.
- Liens and levies are governed by State law.
- State law on the use and execution of liens and levies vary.