Be it resolved that the National Child Support Enforcement
Child Support Enforcement to:
1. Adopt a single standardized format for conducting and reporting Financial institution data matches; and
2. Establish a single centralized nationwide data match process for financial institutions that operate in more than one state.
Title III, Subtitle G, Section 372 of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) requires each state to implement and maintain a data match system with financial institutions for locating the assets of child support debtors. It mandates that financial institutions provide automated customer account information on a quarterly basis to the state(s) in which they operate. The information will be matched against the state's child support debtor information, if an asset is located through this quarterly match, states shall pursue a lien again the debtor's account.
NCSEA has testified before Congress in support of the Financial Data Match (FIDM),, recognizing that a significant amount of delinquent support can be recovered from assets locate through the quarterly data match. NCSEA believes that it is reasonable to pursue FIDM implementation strategies that ease the fiscal burdens of compliance on financial institutions and states. Therefore, NCSEA endorses a standardized format for conducting and reporting data matches. Nationwide uniformity in formats will minimize financial institution expenses and speed the development of software to process the required data. Representatives of financial institutions believe that a single standardized format is essential to the successful implementation of FIDM.
Centralization of data processing will also minimize financial institution expenses since many financial institutions operate in more than one state. In fact, many operate in all 54 states and territories. Centralization will dramatically reduce the required number of quarterly data exchanges and the related costs for interstate financial institutions; it will reduce the cost of operations in each state as well. A precedent for this proposal is the PRWORA provision allowing multi-state employers to report new hires to one state. Therefore, NCSEA endorses the concept of a consolidated Financial Data Match system which would, 1) receive files on child support debtors from the states; 2) send a consolidated file to participating financial institutions; 3) receive matched account information from financial institutions; and 4) return the matched account information to the, appropriate state for action,
The resolutions outlined above recognize the, interstate nature of child support enforcement and the interstate operations of many financial institutions, These resolutions are intended to promote the successful implementation of FIDM while attempting to minimize costs to financial institutions and the states.