New York

Financial Institution Data Match and Automated Asset Seizure Process (FIDM)

Goals: Using technology and private sector resources, implement a financial institution data match coupled with an asset seizure process that is quick and straightforward.

Description: The State's Child Support Management System (CSMS) implemented a full-scale in-state and multi-state financial institution data match. Information about assets of child support obligors is being obtained from banks, credit unions, and securities firms. The assets include savings and checking accounts, IRAs, CDs, mutual funds, cash accounts, and stocks. Financial institutions operating solely within New York State are required to conduct the match directly with the State. Those operating in more than one State may choose to conduct the match with each state in which it operates or directly with the Federal government.

CSMS operates the system as a single process whether the match is facilitated at the federal level or conducted directly with the state. The communication link is to and from the State's mainframe computer. The information is established, checked and routed by CSMS. Data records are applied to all corresponding child support obligor cases maintained by CSMS. As soon as a child support obligor's CSMS account meets the predetermined selection criteria (at least two months delinquent, no payment during the previous 45 days and at least $300.00 past due), the financial asset record linked to the obligor's CSMS account enters the automated asset seizure process. Issues arising from due process remain the responsibility of local support collection units (for example, determination as to the validity of a claim of mistake of fact).

The Office of Temporary and Disability Assistance, parent agency of the Division of Child Support Enforcement, has entered into a contract with a firm to perform the initial and on-going data match with those financial institutions operating solely within New York State (nearly 800 banks and credit unions). It was determined that the hiring of a vendor would be the most cost efficient and effective means of facilitating the data exchange. As of December 31, 2001, there has been nearly 95% compliance on the part of the banks and credit unions.

A contractor was selected, through a competitive bidding process, to coordinate and conduct a quarterly data match of child support records with all of the financial institutions doing business in New York State. The contract deliverables include the following:

Outreach to Financial Institutions

• Identify all eligible financial institutions.

• Provide outreach materials to financial institutions, which clearly describe the matching process, and solicit participation in the process.

  • New York State-specific FIDM Handbook
  • Workshops
  • FIDM video and brochure
  • FIDM website at www.dfa.state.ny.us
• Develop, with state approval, a standard written agreement form to be executed with each financial institution.
• Contact financial institutions to execute the written agreement and begin the match process.
• Develop a timetable for each financial institution leading to completion of the first actual match with each financial institution.
• Offer each financial institution the option of selecting either Match Method 1 or 2 in the federal format as well as media and transmission options.

Approach to Ongoing Operations

• The contractor receives electronically from the State obligor information via a weekly secure file transfer, using FTP.

• The contractor uses the weekly data received to perform quarterly data matches with financial institutions using the federal format and the match method chosen by each financial institution.

  • The contractor receives account records from Method 1 financial institutions on a quarterly basis and conducts the match with the inquiry records received from the State within five (5) business days of receipt.
  • The contractor sends the State's inquiry file to Method 2 financial institutions on a quarterly basis and receives match records back from the financial institutions. The contractor monitors the compliance with the 45-day response deadline and performs follow-up.
• The contractor submits the matches received or made during the prior week to the State on the following Friday.
• The contractor monitors compliance with the match schedule by each financial institution and conducts follow-up.

The Help Desk

The contractor has established and maintains a help line for financial institution questions regarding the FIDM process. This includes status inquiries, technical information, data match assistance, and other customer services-related tasks associated with or as result of the FIDM. The help line is available at a toll-free 800 number and is available from 8:00a.m. to 7:00p.m. eastern time.

Results: In just over a year of full operation, over $8 million has been collected as a result of the FIDM/Asset Seizure Process.

Funding: No special funding is required. Cost is shared with the Federal government as a normal IV-D expenditure.

Replication Advice: Full automation is the key to a successful FIDM and asset seizure process. The system can include strategies for managing matches returned by the data match, including system edits. All records can be processed the day received or as soon as workable. Only valid name and Social Security number (SSN) combinations should enter the automated asset seizure process. Obligor address information can be routed to a separate "parent locator" report process. Asset record types can be screened to bypass non-eligible asset types such as mortgage escrow accounts. The system can identify financial institutions (out-of-state) that do not accept direct liens/levies. Such records can be automatically reported to line workers so as to initiate a two-state process or other interstate enforcement.

Consider strategies for issuing large volumes of liens and levies. The system can select direct liens and levies. The system can "stream out" liens and levies when certain criteria or thresholds are reached. Consider strategies for handling particular asset types such as individual retirement accounts. Strategies for interacting with account holders are also important.

Contact:

Larry Knowles

New York State Office of Temporary and Disability Assistance

Division of Child Support Enforcement

40 North Pearl Street, 13-D

Albany, New York 12243-0001

phone (518) 486-5461

fax (518) 486-3127

e-mail: Lawrence.Knowles@DFA.State.NY.US