What is the purpose of FIDM?
FIDM was passed by Congress as an innovative provision of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), also known as the Welfare Reform Act. The purpose of the provision is to help states increase and accelerate delinquent child support collections. Its intention is to move families off public assistance by helping them become self-sufficient.
Is FIDM compliance required?
Yes. States are required by the federal government to enter into agreements with financial institutions doing business within their boundaries to perform a quarterly data match. State child support enforcement office records of parents, delinquent in their child support payments are matched to accounts held at financial institutions.
What financial institutions must participate in the Data Match Program?
Banks and savings and loans, federal and state credit unions, benefit associations, insurance companies, safe deposit companies, money-market mutual funds, and similar institutions. The types of financial institutions required to participate in data matching may vary from state to state. To see your state's specific list, go to the Financial Institutions information page and check-in.
What types of accounts are subject to the Data Match Program?
FIDM Demand deposit accounts, checking accounts or negotiable withdrawal order account, savings accounts, time deposit accounts, money-market mutual fund accounts. The types of accounts targeted for data matching vary from state to state. To see your state's specific list, go to the Financial Institutions information page and check-in.
How often must the data match be conducted?
It must be performed each calendar quarter.
What data is returned to the state's child support for use in collecting delinquent child support obligations?
Financial Institutions are required to provide the name, record address, social security number or other taxpayer identification number, and other identifying information for each match. It is a format similar to the federal 1099 reporting requirement.
What is the methodology of perfoming the data match?
The record layout is contained in the Data Specifications Handbook (latest edition). Alliance states offer two methods to financial institutions: Method One (the all accounts method) and Method Two (the matched accounts method). You may download the latest version of the Data Specifications Handbook on this website. (
click here)
How does Method 1, the all accounts method, work?
Financial Institutions submit a file identifying all open accounts to Informatix, Inc. on magnetic media, or downloaded through the FIDM Alliance secure website. Informatix then conducts an internal match against delinquent obligors supplied by the state's chils support program. Some Alliance states may require only one All Accounts submission annually, followed by quarterly updates of accounts opened or closed. To see your state's specific list, go to the Financial Institutions information page and check-in.
How does Method 2, the matched accounts method work?
Informatix, Inc. submits the state's child support program inquiry file, containing delinquent obligor's, to the financial institution.The financial institution conducts an internal match against its open accounts.
The financial institution returns a file to Informatix on either electronic media or downloaded through the FIDM Alliance website that contains information on all accounts maintained by individuals on the inquiry to the child support program reporting file.
The match report must be returned to the State within 30-45 days of receipt of the inquiry file. The child support program may issue liens and levies to attach and seize the asset(s) of the delinquent obligor.
What types of agreements are necessary?
States must enter into agreements with every financial institution doing business within the state. Financial institutions doing business only within one state must make its agreement with that state. In the case of multi-state financial institutions, they may either enter into an agreement with the state or with the federal Office of Child Support Services. If your FI is doing business in one of the 22 Alliance states, your state's specific agreement is available on this website. To learn more go to your Financial Institutions information and check-in.
How is data exchanged?
Financial institutions in Alliance states, using either Method 1, or Method 2 may elect to exchange data in several ways. Data may be physically exchanged on paper or electronic media and sent to Informatix for processing. Or it can be downloaded to or from Informatix's FIDM Alliance secure website for quick easy processing. Informatix has worked out protocols for all the data formats and maintains testing software so that the exchange process can be tested off-line prior to live exchange.
What kind of media can I use?
The Informatix FIDM Alliance website, utilizing E-match Solutions electronic exchange over the internet is the most expedient way. But, if financial institutions prefer, they may use any of the following media to exchange data match information:
CD
Paper
Secure Internet
SFTP
What if my FI uses a service provider?
Simply select the FIDM Alliance reporting method you prefer, and instruct your service provider to work with Informatix, Inc. to work out the details.
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 Services for this purpose.
The Work Group members provide advice on agreements, fees, operations, and outreach efforts. The Work Group developed uniform data specifications that are used by all states, territories and financial institutions to conduct the data match.
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 FIDM. 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 (i.e., those financial institutions operating within two or more states).
All States and territories have laws in place to meet the FIDM requirements of PRWORA. If you are doing business in a FIDM Alliance state, and wish to see your state's law go to Financial Institutions information and check-in.
Must states pay a fee to financial institutions for conducting the data match?
State law determines whether a State will pay a fee or not. Fees must not exceed the actual costs of conducting the match. Federal financial participation (FFP) is available to partially reimburse the states for the cost of "reasonable" fees paid to the financial institution for the data match. If you are doing business in a FIDM Alliance state, and wish to see your state's law go to Financial Institutions information and check-in.
Can a financial institution be held liable for the release of account information relating to the FIDM program and the levies that may result?
No. Both federal and state laws protect financial institutions from liability if they are in good faith compliance with FIDM reporting requirements.
Section 466(a)(17)(C) of the Social Security Act establishes that a financial institution shall not be liable under any federal or state law to any person for any disclosure of information to the State IV-D agency under section 466(a)(17)(A)(i) of the Act.
Similarly, financial institutions shall not be liable under any federal or state law for encumbering or surrendering any assets they hold in response to a notice of lien or levy issued by the IV-D agency.
Financial institutions will not be held liable for any other action taken in good faith to comply with the requirements of section 466(a)(17)(A) of the Act.
If you are doing business in a FIDM Alliance state, and wish to see how your state's law deals with the liability issue, go to Financial Institutions information and check-in.
How can I obtain additional information?
Financial institutions may contact their State/professional associations or their State Child Support (IV-D) office. Alliance state's contact information is available on the Sign-Up Information page at this website, just go to the Financial Institutions information page and check-in.