In Dear Colleague Letter DCL 98-120 dated November 16, 1998, OCSS sent each IV-D Director a Certification Addendum to the OCSS Debtor File (also known as the Federal Offset File). By signing the Addendum the IV-D Director transfers to OCSS the responsibility for reaching agreements with multistate financial institutions (MSFIs) on behalf of their State.
In 1998, OCSS identified over 3,000 MSFIs by accessing information from the Federal Deposit Insurance Corporation, National Credit Union Association, Securities Industry Association and National Securities Clearing Corporation's websites. OCSS sent correspondence to the MSFIs that included an overview of the multistate financial institution data match (MSFIDM) process, data match specifications and an election form to participate in the MSFIDM program. The election form serves as the operational agreement between the MSFI and OCSS and must be signed by an authorized representative. The form also serves a the mechanism that allows the institution to opt out of the data match at the federal level in favor of participating in the data match with each state and territory where the MSFI does business.
Each month OCSS sends states and territories a list of MSFIs that have completed an election form in the previous month to participate in the MSFIDM program. When an MSFI elects not to participate in the MSFIDM program, OCSS sends written notification to each state and territory where the MSFI does business alerting them that the MSFI will participate in the data match at the state level.
MSFIDM process:
- Each week states update the OCSS Debtor File, a national file of individuals who owe past-due child support.
- States have the option to exclude cases on the Debtor File from MSFIDM by setting the "FIN" exclusion indicator.
- To create an inquiry file to send to MSFIs, the MSFIDM program extracts eligible obligors' names and social security numbers (SSNs) from the Debtor File.
- The MSFIDM program compares the name/SSN combinations on the inquiry file with the Social Security Administration (SSA)'s records to determine that the SSN/name combinations submitted by states is valid. Name/SSN combinations that are not valid are dropped from the inquiry file.
- To ensure MSFIs receive only one name/SSN combination per record, the MSFIDM program removes duplicates from the inquiry file. Duplicate records occur when two states submit the same MSFIDM eligible obligor.
- OCSS sends the inquiry file to MSFIs to compare with their account records.
- MSFIs return matches to OCSS in the MSFIDM response record.
- OCSS edits the response file and distributes the MSFIDM eligible matches to the state(s) that submitted the obligors on the Debtor File within 48 hours of receiving the response file from MSFIs.
OCSS does not take action to collect money from accounts identified though MSFIDM. To assist with financial institution billing and State reimbursement, OCSS provides each participating MSFI or their designated transmitter with the following information at the end of each quarter:
- Total number of MSFI accounts matched
- Distribution of the matched data on a State by State basis
- List of States that have agreed to pay a reimbursement fee for the data match, the reimbursement fee amount and the billing address if the MSFI elects to pursue cost recovery.