crossing borders and overcoming barriers – interstate fidm (financial institution data match) 1...
TRANSCRIPT
Crossing Borders and Overcoming Barriers –
Interstate FIDM(Financial Institution
Data Match)
1
Moderator: Caroline Pierce, Senior Manager, Informatix, Inc.
Speaker: Matt Marsolais, OCSE Analyst
Speaker: Andrew Szymak, Oklahoma FIDM Coordinator
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 4th 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 1st quarter 2010
TSP Progress
• Conducted first match January 31st, 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 LayoutsColumn 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
Amount 64 69 6 Numeric
Filler 70 73 4 Numeric
Withheld Date 74 81 8 Numeric
Passback 82 121 40 Text
Account Number 122 136 15 Numeric
Filler 137 141 5
Match Type Code 142 142 1 Text
Name Format 143 143 1 Text
Name Order 144 144 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 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
Amount 64 69 6 Numeric
Threshold Amount 70 73 4 Numeric
Request Date 74 81 8 Numeric
Passback 82 121 40 Text
Filler 122 175 54
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.
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* GuamIllinois** 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
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 $750K 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
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
AEI request acknowledgements from assisting states are sent via e-mail
“New action” or “change action” notifications are sent by e-mail
IDEC electronic AEI referral system cont.
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: [email protected]