Crossing Borders and Overcoming Barriers – Interstate FIDM (Financial Institution Data Match) Moderator: Caroline Pierce, Senior Manager, Informatix, Inc. Speaker: Matt Marsolais, OCSE Analyst Speaker: Andrew Szymak, Oklahoma FIDM Coordinator 1
OCSE Programs & Initiatives • Multistate Financial Institution Data Match (MSFIDM) – Statistics – Upload/Download • Thrift Savings Plan (TSP) • Proposed Federally Assisted State Transmitted (FAST) Levy Project
MSFIDM Statistics • Over 4, 600 financial institutions participating • Record total of $129 million voluntarily reported in 2010 • 3. 8 million matches returned in 4 th quarter 2010, associated with 1. 7 million SSNs. • Monthly reports / limited service spreadsheet
OCSE e-Portal • MSFIs able to download and upload quarterly files from a secure website • Authentication and registration
Thrift Savings Plan (TSP) • Background – Retirement plan offered to federal civilian and military employees – Administered by the Federal Retirement Thrift Investment Board (FRTIB) – 4. 3 million participants – OCSE began matching with TSP in 1 st quarter 2010
TSP Progress • Conducted first match January 31 st, 2011 • Over 81, 000 matches returned to states through FCR • States able to use Federal Lien Form, IWO, or state-specific form to garnish TSP accounts, pending the form includes required information by TSP (next slide) • $45, 000 voluntarily reported collections
Garnishing TSP Accounts • Requirements – “TSP” or “FRTIB” must be specified on form – Must specify type of account (e. g. military/civilian) – Must specify dollar amount – Name of participant and participant SSN • Fax is preferred method of receipt – (703) 592 -0151
Proposed FAST Levy Project • OCSE portal as a delivery mechanism for states sending freeze requests to FIs. • Advantages – Eliminates paper – Quicker process – States and FIs send information to a single location (OCSE’s portal)
FAST Levy Processing Options • System to System • No Programming for states or employers— Excel Spreadsheet or PDF – Success with e-IWO • User Interface • Options
Current US Bank / WA State Electronic Levy Process • Automated levy process • File transmission occurs daily • Payments are sent from US Bank to WA SDU via ACH
US Bank / WA Record Layouts Column From To Length Data Type Record ID 1 2 2 Text Response Code 3 4 2 Numeric SSN 5 13 9 Numeric Last Name 14 34 21 Text First Name 35 44 10 Text Middle Name 45 54 10 Text DOB 55 62 8 Numeric Match Indicator 63 63 1 Numeric DOB 55 62 8 Numeric Amount 64 69 6 Numeric Match Indicator 63 63 1 Numeric Filler 70 73 4 Numeric Amount 64 69 6 Numeric Withheld Date 74 81 8 Numeric Threshold Amount 70 73 4 Numeric Passback 82 121 40 Text Account Number 122 136 15 Numeric Request Date 74 81 8 Numeric Filler 137 141 5 Passback 82 121 40 Text Match Type Code 142 1 Text Filler 122 175 54 Name Format 143 1 Text Name Order 144 1 Text Filler 145 175 31 Text Column From To Length Data Type Record ID 1 2 2 Text Action Code 3 4 2 Numeric SSN 5 13 9 Last Name 14 34 First Name 35 Middle Name
FAST Levy Progress, Barriers & Next Steps • Progress – Conference calls with states and FIs – OCSE currently in research, analysis, and feasibility stage. • Barriers – Legislation requiring states to send freezes and seizes via certified mail. – Over collecting if an NCP has multiple bank accounts at separate institutions. • Next Steps – OCSE to schedule follow up conference calls with states and FIs.
Questions / Comments Matt Marsolais OCSE Analyst Matthew. marsolais@acf. hhs. gov (202) 260 -5479
Interstate FIDM How Oklahoma attaches FIDM assets located in other states
Issues arising from attaching out-of-state FIDM accounts: § § Access to out-of-state FIDM matches State laws Financial institutions Implementation of state systems and procedures to attach out-of-state FIDM assets
Access to out-of-state FIDM matches: Two sources of matches § Multi-State FIDM (e. g. , Bank of America, Chase, Regions, Wells Fargo) § In-state matches § In-house § Alliance or consortium
FIDM Alliance • Made up of 18 states entering into an Alliance to outsource in-state FIDM programs. • Formed to cooperatively develop, issue and oversee these FIDM operations. • Cross border FIDM matching done on a state to state agreement basis. • Each participating state is responsible for entering into individual contracts with the selected contractor that oversees the program. • Texas is the lead state of the Alliance for the purpose of procurement.
Interstate Data Exchange Consortium - IDEC Oklahoma receives its Interstate FIDM matches through IDEC. What is IDEC? § A partnership of 15 states for the collection and enforcement of child support § Access to accounts in all member states § Operated as a state-administered, state-owned system § Managed by the State of South Carolina
FIDM Limited Partnerships • IDEC offers a Limited Partnership that allows non -member states to participate in the quarterly interstate matching of Full Member states • Limited Partners become reciprocal partners with IDEC member states • No change is necessary to existing systems, software or vendor contracts. • Access to accounts in all IDEC member states and access to Automated Enforcement of Interstate Cases (AEI) Web site.
Two types of Limited Partnerships with IDEC • FIDM Alliance member states • Independent FIDM states
State laws Each state or territory established its own FIDM laws. The following jurisdictions allow direct levies: Delaware* Guam Illinois** Louisana* Massachusetts Michigan** New Jersey** Nevada** New Mexico* New York** North Carolina* South Carolina* Texas** *Indicates IDEC member states **Indicates FIDM Alliance member states
Special circumstances with direct levy states § Send cover letters or copies of levy statutes § Special rules for certain financial institutions (e. g. , Wells Fargo, USAA) § Some financial institutions do not cooperate (Oppenheimmer Funds)
Financial institutions that provide direct access for Oklahoma: Bank of America JP Morgan Chase Wells Fargo Citibank Regions Fifth Third Bancorp Various brokerage houses
Quarterly lists provided by OCSE § Regionalized list § MSFIs likely to accept direct actions § MSFIs not accepting direct actions
Attaching out-of-state FIDM assets Oklahoma uses an auto FIDM analyzer program § All FIDM matches go through the auto analyzer § Programming reviews states where the accounts are located (looks for direct levy states) § Programming reviews for financial institutions that accept direct levies (collected $750 K since January 2010)
Manual list for FIDM matches that do not go to Auto Workers are provided weekly lists for review with instructions on processing various manual FIDMs § Direct levy § Needs cover letter § Can use only Limited Services/Automated Enforcement in Interstate cases (AEI) to attach the account
Submitting Limited Service/AEI referrals § Traditional paper method § Send UIFSA 1 or 3 transmittal form § Include additional documentation (e. g. , copies of orders and arrearage computations) § IDEC electronic AEI referral system § Web-based system to submit AEI referrals among member states
IDEC electronic AEI referral system § Used for in-state and MSFIDM matches § Each state identifies unique business rules for freeze and seize thresholds (account balances, types of accounts, etc. ) § Member states control the number of requests for assistance allowed by adjusting thresholds
IDEC electronic AEI referral system cont. § AEI request acknowledgements from assisting states are sent via e-mail § “New action” or “change action” notifications are sent by e-mail
Oklahoma Interstate FIDM checklist § Will the financial institution accept a direct levy? Look at the financial institution and the state where it is located § If both state and the financial institutions do not allow for direct levy, review whether state will accept an AEI referral § If state where funds are located is an IDEC member, review freeze and seize requirements: is an electronic AEI request possible?
Contact Andrew Szymak Oklahoma Child Support Services FIDM Coordinator Phone: (405) 522 -6230 Fax: (405) 522 -4570 E-mail: Andrew. Szymak@okdhs. org
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