Answers to the Most Frequently Asked Questions

What is the purpose of the Financial Institution Data Match (FIDM)?

The purpose of FIDM is to bring monetary aid to children by identifying accounts belonging to delinquent obligors. Once identified, these accounts may be subject to wage garnishment, liens, and levies issued by state or local child support enforcement agencies.

What legislation established the FIDM program?

Public Law 104-193, the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), also known as the Welfare Reform Act, contains the provisions for the Financial Institution Data Match (FIDM). Also, Public Law 105-200, the Child Support Performance and Incentive Act of 1998, modified PRWORA to better facilitate the data match for multi-state financial institutions. All States and Territories have laws in place to meet the FIDM requirements of PRWORA. Reference RSMo 454.507.

Who decided how FIDM should work?

The Financial Institution Work Group, comprised of representatives from financial institutions and their associations, third-party processors, software providers, and Federal and State child support representatives, serves as an advisory group to the Federal Office of Child Support Enforcement (OCSE) for this purpose. The Work Group members provide advice on agreements, fees, operations, and outreach efforts. In addition, they develop uniform data specifications which will or are being used by all States, Territories, and Financial Institutions to conduct the data match.

Should the financial institutions that exchange data be concerned about privacy issues?

Child support programs have very tight confidentiality restraints and this is no exception. It is clear that data match information must be used only to locate assets and enforce child support orders. Further, the state has designed a system that is not intrusive and is highly confidential. Under PRWORA, a financial institution will not be liable under any Federal or State law to any person for certain disclosures of data match pursuant to the act. Reference 42 U.S.C. Section 666(a)(17)(C).

Will there be any reimbursement for costs incurred by compliance with this program?

The Family Support Division will reimburse financial institutions conducting the FIDM match actual costs incurred up to $75 per quarter. To date, many institutions have indicated a willingness to conduct matches at no cost due to the purpose of the law, which is to assure that children receive the financial support that they are due from their parents.

How is a financial account defined?

RSMo 454.507 defines an account as: a demand deposit, checking or negotiable withdrawal order account, savings account, time deposit account or money market mutual fund account or individual retirement account qualified pursuant to Section 408 or 408A of the Internal Revenue Code.

What information is returned through FIDM?

Name of account holder, record address, social security number or other taxpayer identification number, and other identifying information. Refer to the Financial Institution Specifications Handbook for the detailed record layout.

How often will financial institutions be required to submit match information?

Institutions must submit information quarterly. Institutions select the month and week of each calendar quarter to transmit or perform the data match and transmit.

What data specifications are to be used for the transfer of data?

Missouri has adopted a record layout of information that is based on the Financial Institution Data Match Specifications Handbook. The handbook can be found at https://www.acf.hhs.gov/sites/default/files/documents/ocse/msfidm_specifications_handbook.pdf.

How can I obtain additional information?

If you have questions regarding agreement processing, technical support, scheduling, or status verification, please call the Missouri Financial Institution Data Match customer support center
toll-free at 1-866-646-7711 between 8:00am and 5:00pm Central Time.

• RSMo 454.507: https://revisor.mo.gov/main/OneSection.aspx?section=454.507&bid=48007&hl=
• Federal Office of Child Support Enforcement Website for Financial Institution Data Match: http://www.acf.hhs.gov/programs/css/financial-institutions

How is the Family Support Division going to decide which accounts to seize?

The Family Support Division will look at the specific circumstances in each case in determining whether or not to seize an account.

Will the Family Support Division be taking complete balances from all accounts?

Decisions regarding how much of an account to seize will depend on the amount owed and the type of account. Any account of less than one hundred dollars will not be seized.

What about co-owners, how will they be protected?

See RSMO 454.507.

How does Method One, the All Accounts Method, work?

• Financial institutions submit a file identifying all open accounts to the Family Support Division.
• The Family Support Division conducts an internal match against delinquent obligors.

How does Method Two, the Matched Accounts Method, work?

• The Family Support Division provides an inquiry file, containing delinquent obligors, to the financial institution.
• The financial institution conducts an internal match against its open accounts.
• The financial institution sends a file to the Family Support Division that reports information on all accounts maintained by individuals on the inquiry file.

Can a financial institution be held liable for the release of account information relating to the Missouri Financial Institution Data Match program and the levies that may result?

No. Section 466(a)(17)(C) [42 U.S.C. 666(a)(17)(C)] of the Social Security Act established that a financial institution shall not be liable under federal or state law to any person for any disclosure of information to the State IV-D agency.

Financial institutions will not be held liable for any other action taken in good faith to comply with the requirements of FIDM. See RSMO 454.507.