Presentation on theme: "Crossing Borders and Overcoming Barriers – Interstate FIDM (Financial Institution Data Match) 1 Moderator:Caroline Pierce, Senior Manager, Informatix,"— Presentation 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 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 ColumnFromToLengthData Type Record ID122Text Response Code342Numeric SSN5139Numeric Last Name143421Text First Name354410Text Middle Name455410Text DOB55628Numeric Match Indicator63 1Numeric Amount64696Numeric Filler70734Numeric Withheld Date74818Numeric Passback8212140Text Account Number12213615Numeric Filler1371415 Match Type Code142 1Text Name Format143 1Text Name Order144 1Text Filler14517531Text ColumnFromToLengthData Type Record ID122Text Action Code342Numeric SSN5139Numeric Last Name143421Text First Name354410Text Middle Name455410Text DOB55628Numeric Match Indicator63 1Numeric Amount64696Numeric Threshold Amount70734Numeric Request Date74818Numeric Passback8212140Text Filler12217554
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*Guam Illinois**Louisana* MassachusettsMichigan** 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 AmericaJP Morgan Chase Wells FargoCitibank RegionsFifth 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: Andrew.Szymak@okdhs.org