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Frequently Asked Questions

 


 What is the Financial Institution Data Match (FIDM) Program Background?

The Federal Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) initiated major changes in welfare policy. The act was the catalyst for creating many new child support enforcement tools. Since welfare payments are now time-limited, child support is now more important than ever in helping families achieve and maintain self-sufficiency. The financial community at large is mandated to work with each state to create an automated system that matches non-custodial parents delinquent in child support payments to the accounts maintained at the financial institutions. This automated system, generally known as Bank Match Registry or the Financial Institution Data Match (FIDM) must be operational for states to maintain Federal certification and related funding levels.

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 What is the State of Georgia (GA) FIDM Program?

The State of Georgia introduced House Bill 284 in the 1997 legislative session which provided for the creation of an automated application system to meet the requirements of the federal Financial Data Match Program mandate. This bill was passed in mid 1997 and was incorporated in to the Official Code of Georgia Annotated (OCGA) as section 19-11-30. The Department of Administrative Services (DOAS) was chartered to develop the system on behalf of their internal customer agency the Department of Human Resources Office of Child Support Enforcement. In the fall of 1997 work on a preliminary system analysis and data model were started.

A steering committee was assembled and met for the first time in November 1997. The steering committee is made up of representatives of financial institutions (Banks, Credit Unions and Insurance Companies), financial industry associations (Georgia Credit Union Affiliates, Georgia Bankers Association, Community Bankers Association of Georgia), financial industry service providers, DHR/OCSE, DOAS, and other related state entities.

Discussion took place and DOAS was chartered to conduct a pilot project to perform prototype financial data matches with volunteer financial institutions representing a cross section of the financial community. Specifically a credit union, large bank and medium-size bank were targeted. It was expected that these prototype matches would bring forth issues and help to ensure that the final production system met the needs of the entire financial community.

Multiple prototype matches were conducted through Spring and Summer 1998 and the pilot project was expanded to include a survey of the financial community to further determine requirements and preferences. The pilot project match results and survey feedback were presented to the steering committee in June 1998.

A system development effort was undertaken while the pilot process was being conducted. The pilot results and steering committee feedback were taken in to account during the design process. The system design utilized Federal program guidelines that were issued to help ensure cross-state standardization and uniform functionality.

The system development led to the creation of the current GA FIDM Program. This program and the automated system are designed to meet all Federal and State legal requirements as well as those of the participating financial community. The first phase of the system is currently being implemented statewide.

While the Department of Administrative Services is charged with the responsibility of developing and maintaining a computer-based registry of account data obtained from financial institutions, it should be clearly noted that the process of child support establishment and enforcement including any decision to levy matched accounts is under the authority and direction of the Department of Human Resources Office of Child Support Enforcement.


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 What is the Georgia State Law governing the GA FIDM Program?

The program is governed by the Official Code of Georgia, Annotated (O. C. G. A.) section 19-11-30. This legislation can be viewed online at www.ganet.org/services/ocode/ocgsearch.htm. This link may be accessed through the GA FIDM web site at www.state.ga.us/Departments/doas/bankmatch.

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 Which Financial Institutions (FIs) are required to participate?

The financial institutions required to participate in the Financial Institution Data Match Program are every federal or state chartered commercial or savings bank, including savings and loan associations and cooperative banks, federal or state chartered credit unions, benefit associations, insurance companies, safe-deposit companies, trust companies and money market mutual funds.

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 What are the Targeted Financial Account Types?

For the purpose of the Financial Institution Data Match program "account" means a demand deposit account, checking or negotiable order of withdrawal account, savings account, time deposit account, or a money market mutual fund account. Whole life insurance policy accounts with cash values are also addressed via federal legislation.

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 What are the GA FIDM Program Logistics?

Financial institutions are required sign and return to the state a written Financial Institution Agreement with DHR and a Financial Institution Data Match Set-up Form.

Participating financial institutions may designate a reporting agent (service provider) to perform required state processing for them. If this is desired, the appropriate fields must be filled out on the Financial Institution Data Match Set-up Form. Computer-readable media and/or printed report of regional delinquent child-support obligors will be sent to participating financial institutions or their agents on a quarterly basis. The Federal Offset File will also be sent to the federal Financial Institution Data Match (FIDM) system for processing. The federal FIDM will perform matching for financial institutions that do business in two or more states.

The financial institution/agent has 30 days to perform an account lookup (primarily on social security number) for all of their applicable accounts. The matched account information is then sent back to the state (or a state-designated service provider) on computer-readable media along with a paper transmittal form.

The state (or a state-designated service provider) processes and passes this account information to DHR/OCSE for additional research which may lead to seizure and disbursement of any available funds.

Each account and the related case will be fully researched by DHR/OCSE field case agents prior to any levy of funds occurring.

Matches from the federal FIDM will also be processed and passed to DHR/OCSE for follow-up.


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 Who funds the FIDM Program Development Costs?

The state funded the cost of developing this federally mandated automated computer application system. Financial institutions fund their mandatory participation in terms of costs for system revision/development. Financial institutions may file for reimbursement of actual technical costs as provided by law. The Department of Human Resources may pay a reasonable fee to financial institutions for conducting the required searches, however the cost cannot exceed the actual cost incurred by the financial institution or $100 per quarter, whichever is less.

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 What is the FIDM Program Standardization?

This system is based on federal specifications jointly developed with financial industry workgroups at the federal level in 1997 and 1998 and finalized March 5, 1999. The specifications are largely based on the Massachusetts Financial Data Match Program which was the first program running live in the United States. National state level development of financial institution data match systems is being standardized as much as possible to ensure compatibility in the case of future processing consolidation at a regional or national level.


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 Where is the Federal FIDM Program Specifications?

The latest Federal FIDM Specifications can be downloaded from the GA FIDM web site at www.state.ga.us/departments/doas/bankmatch.

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 What is Method 1 processing (the all accounts method) referenced in the Federal FIDM specifications?

The all accounts processing method 1 is where a financial institution sends the State a file quarterly identifying all open accounts. The state then does in-house matching and subsequent processing.

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 Is Method 1 processing (the all accounts method) referenced in the Federal FIDM specifications available in the State of Georgia?

Yes.

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 What is Method 2 processing (the matched account method) referenced in the Federal FIDM specifications?

This is where financial Institutions match account information to a state-supplied file of delinquent obligors on a quarterly basis. The basic process is outlined above in the section: What are the GA FIDM Program Logistics?

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 Is Method 2 processing (the matched account method) referenced in the Federal FIDM specifications available in the State of Georgia?

Yes.

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 What is the Federal Financial Institution Data Match (FED FIDM) Program?

A memo number DC-98-69 was sent from The U.S. Department of Health and Human Services, Administration for Children and Families, Office of Child Support Enforcement's Commissioner, David Gray Ross to State IV-D Directors and Financial Industry Workgroup Members on July 28, 1998.

 

This memo highlights a multi-state Financial Institution Data Match (FIDM) federal program mandated by HR3130 to process data matches nationwide for those financial institutions doing business in two or more states. As of this time only multi-state financial institutions will be processed at the federal level. The multi-state institution has an option of participating in the FIDM program with either the individual states or with the Federal FIDM. They must complete the Multistate Election form located on the Federal Office of Child Support Enforcement's Website at www.acf.dhhs.gov/programs/cse/fct/fidm/docs/elecform.pdf. The state will receive and process information on matched accounts from the FED FIDM.

*For additional information or to check on the current status of this program, please call 410-277-9312 or e-mail: fidm@ssa.gov.

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 What is the Southeast Regional FIDM Consortium?

The State of Georgia is participating in a Southeast Regional FIDM Cooperative Program that is being operated by the Southeast Regional Electronic Parent Locator Network (EPLN) Consortium service provider TransFirst. Participating regionally provides an economy of scale cost savings in implementing intrastate and interstate FIDM programs as required by federal legislation.

 

All financial institutions in consortium member states will receive a consolidated file of delinquent obligors for all states that are a member of this consortium. The FIs will then perform a match process on this consolidated file and return matched account information. The matches will then be forwarded to the originating state for follow-up processing and collection/disbursement of funds where appropriate.

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 What are the Media Choices available?

Any combination of the following are currently available for use in quarterly processing from the state.

 

Magnetic Media Choices:

  • 3480/3490 cartridge
  • 3590 cartridge
  • 9 Track Round Reel
  • 3-1/2" High Density Diskette
  • CD-ROM
  • FTP Transmission, when available

 

A Financial Institution may request a printed report from the state, but the Matched Account File that the FIs send to the state must be submitted in machine readable form. The printed media choices are available as follows:

 

  • Report of Delinquent Obligors in Social Security Number Sequence
  • Report of Delinquent Obligors in Delinquent Obligor Name Sequence

 

The Inquiry File contains highly confidential data. Therefore all Method Two filers are to return the Inquiry File with their Data Match File.

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 What are the common media and format errors encountered?

The Department of Administrative Services encourages filers to verify the content of their FIDM tapes to ensure the accuracy of the data. This may eliminate the need for TransFirst to return your tape for correction. This is especially important to those who have their reports prepared by a Reporting Agent.

 

Rejected tapes will be returned to the filing institution with a letter explaining the reason for rejection. The institution is to make the appropriate corrections and resubmit the tape as soon as possible.

The following are frequently encountered problems that have been found in the FIDM tape process.

Generally:

 

Non-interest bearing accounts omitted or excluded.

Although such accounts may be exempt from IRS 1099 reporting, these accounts are not excludable under O.C.G. A 19-11-30 governing the Financial Institution Data Match Program.

 

Transmitter TIN/FID omitted.

 

"A" Record: The institution or money market fund TIN/FID is omitted, positions 007-015. Only numerals are to be entered in these positions. Hyphens and blanks between digits are also common errors.

 

Levy service mailing address is incorrect or omitted, positions 131-210.
The levy service address may be different from your institution's general street address.

 

"B" Record: Account Balance is omitted, positions 351-357

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 What are the Required Program Forms?

When communicating with the State concerning FIDM issues we require that you submit the proper forms along with any feedback that you may have. The forms are as follows:

  • DHR Financial Institution Agreement
  • Financial Institution Data Match Set-up Form

These forms are contained in our website and can be downloaded as needed using an Adobe Acrobat reader.

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 How can participation start in the FIDM Program?

The authorized person representing the financial institution must fill out and submit the DHR Financial Institution Agreement Form and the Financial Institution Data Match Set-up Form to the FIDM program administrator.

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 Are financial institutions and/or their agents liable for disclosing account information to the state?

No. Section 19-11-30.9 of the O.C.G.A states that, "A financial institution shall incur no obligation or liability to a depositor or account holder or any other person arising form the furnishing of a report or information to the Department of Administrative Services." Additionally, 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 for the disclosure of information to the IV-D agency under the data match program. Also financial institutions shall not be held liable for encumbering or surrendering any assets they hold in response to the lien or levy issued by the IV-D agency (DHR). Section 469A further provides that the financial institutions shall not be held liable for release of appropriate information to the Federal Parent Locate System (FPLS) under the multi-state data match program.

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 Where should the State of Georgia FIDM forms and files be sent?

For security purposes all media must be sent via a secured traceable method. Examples of these methods are Federal Express, UPS Ground Track, etc. All Financial Institution Data Match Program media must be sent to: Electronic Parent Locator Network, TransFirst, Inc., 3988 N. Central Expressway, Building 5, 2nd Floor, Dallas, Texas 75204, ATTN: Lorrie Winters.

All FIDM Forms must be sent to: Georgia Department of Human Resources, Office of Child Support Enforcement, 2 Peachtree Street, 20th Floor, Atlanta, GA 30303, ATTN: Janice Alford, Agency FIDM Coordinator.

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 How will the situation of no account matches for a quarter be handled?

Those filing under Method 2 may have no matches to report after comparing their accounts against the DOAS Inquiry File. No Match directions may differ depending on who is filing the report. Please read the following sections carefully to find which apply to you.

 

Reporting Agents

If a Reporting Agent finds one or more institutions for which it reports do not have a match against the Inquiry File, follow these instructions:

 

a) Agents reporting both matches and no matches, must include a complete "A" and "T" Record on the Match Tape for every institution it compares against the Inquiry File. Do not omit those institutions with no matches, but enter zeroes in the appropriate positions of the "T" Record. An institution that has been omitted may find itself in violation of Bank Match requirements. A No Match Report must be filed by completing a Magnetic Media Transmitter Report. Attach a list containing every institution name, TIN and the total number of accounts compared against the Inquiry File for each.

 

b) Agents reporting for a single institution may follow the single institution instructions below.

 

All Other Institutions

Financial institutions finding no matches after comparing its accounts to the Inquiry File must complete both the "A" and "T" record on the Match Tape for the institution. Zeros must be entered in the appropriate positions of the "T" record. A No Match Report should also be filed by entering "No Matches" on a completed transmittal report. Include the total number of accounts compared against the Inquiry File.

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 How can a Reporting/Processing Agent (a/k/a Service Provider) be designated?

If the Financial Institution elects to use a Reporting/Processing Agent to do the Financial Institution Data Match the appropriate fields in the Financial Institution Data Match Set-up Form must be filled out by the Financial Institution and mailed to: Georgia Department of Human Resources, 2 Peachtree Street, 20th Floor, Atlanta, GA, 30303, ATTN: Janice Alford, Agency FIDM Coordinator. Otherwise DHR will send the Delinquent Obligor file to the institution at the address maintained in the database of DHR.

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 Are there penalties for not reporting information to the state?

Yes. Any financial institution required to submit a report pursuant to Code Section 19-11-30 which fails without reasonable cause as determined by the state after notification shall be liable for a penalty of $1,000. Any financial institution which willfully provides false information in reply to such notification shall be liable for a penalty of $1,000.

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 What is on the program web site?

Documents included on this website and available for download are as follows:

  • DHR Financial Institution Agreement
  • Financial Institution Data Match Set-up Form
  • Federal Financial Data Match Specifications Handbook
  • Test ASCII text 99 byte long Inquiry File (1 header record, 12 inquiry records, 1 trailer record. Note: all data elements are fictitious and can be modified for testing purposes.)

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 Where can I get help or additional information?

If you have any questions regarding the file specifications or other technical aspects of the FIDM program, please call Susan Henley at 404-656-6635 or George Lockitt at 404-651-5334. If you have questions concerning the levy process, please contact Erica Thorton with the Department of Human Resources at 404-657-1131.

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