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Crossing Borders and Overcoming Barriers – Interstate FIDM (Financial Institution Data Match) Moderator: Caroline 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 – 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 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 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 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 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 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 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 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 • 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 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 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 Questions / Comments Matt Marsolais OCSE Analyst Matthew. [email protected] hhs. gov (202) 260 -5479

Interstate FIDM How Oklahoma attaches FIDM assets located in other states 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 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. 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 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. 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 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 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 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 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 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 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 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 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 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 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 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 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: Contact Andrew Szymak Oklahoma Child Support Services FIDM Coordinator Phone: (405) 522 -6230 Fax: (405) 522 -4570 E-mail: Andrew. [email protected] org