Form 1 MSFIDM Election Form

Multistate
Financial Institution
Data Match

Including background information,
participation instructions, and
the required form for exchanging data with
the Office of Child Support Enforcement
(OCSE).

Department of Health and Human Services
Administration for Children and Families
Office of Child Support Enforcement
Published: August 2001 Revised: December 2020

Table of Contents
1

Background......................................................................................................... 1

1.1
1.2
1.3
1.4

Definition of Financial Institution ........................................................................... 1
Definition of Account............................................................................................. 1
Who May Match Data with OCSE?....................................................................... 1
What Liability Will Accrue to Financial Institutions? .............................................. 2

2

Data Match Process ........................................................................................... 2

2.1
2.2
2.3
2.4
2.5

Data Specifications ............................................................................................... 2
Types of Transmission ......................................................................................... 2
What Happens When a Match Occurs? ............................................................... 3
What about Fees? ................................................................................................ 3
Security Guidelines ............................................................................................... 3

3

Data Match Timelines ......................................................................................... 4

3.1
3.2

Operational Agreements ....................................................................................... 4
Fee Assessment Information ................................................................................ 4

4

Election Form Instructions ................................................................................ 5

4.1
4.2
4.3
4.4

Due Date .............................................................................................................. 5
Election to Participate ........................................................................................... 5
Election to Use Reporting Agents ......................................................................... 5
Election Form ....................................................................................................... 5

PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) STATEMENT OF PUBLIC BURDEN: The purpose
of this statutorily required (42 U.S.C. § 666(a)(17))] information collection is for child support purposes. Public
reporting estimated burden for this collection of information is .5 hours per respondent, including the time for
reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. As
provided by the 42 U.S.C 653(m), any confidential information collected for this program is authorized users. A
federal agency may not conduct or sponsor an information collection without a valid OMB Control Number. No
individual or entity is required to respond to, nor shall an individual or entity be subject to a penalty for failure to
comply with a collection of information subject to the requirements of the Paperwork Reduction Act of 1995,
without a current valid OMB Control Number. If you have any comments on this collection of information, please
contact OCSEFedSystems@acf.hhs.gov.

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1

Background

Nationally, the number of child support cases increased from two million in 1976 to over 15.7
million in 2020. Committed to improving the lives of children, the federal Office of Child
Support Enforcement (OCSE) worked with state and local child support programs to develop the
Federal Parent Locator Service (FPLS) to help states locate individuals to establish and enforce
child support orders. The Multistate Financial Institution Data Match (MSFIDM) program is part
of the FPLS.
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA),
also known as Welfare Reform, went into effect on August 22, 1996. One provision requires all
states and territories that operate approved child support enforcement plans to enter into
agreements with financial institutions conducting business in their state. The purpose of these
agreements is to identify accounts, through quarterly data matches, that belong to parents who
are delinquent in their child support obligation.
Public Law 105-200, the Child Support Performance and Incentive Act of 1998 changed
PRWORA to improve the data match for multistate financial institutions (MSFIs). This law
authorizes OCSE to act as the conduit between the states, territories, and MSFIs to conduct a
centralized quarterly data match program to identify accounts belonging to individuals who owe
past-due child support.

1.1

Definition of Financial Institution

Section 466(a)(17)(D)(i) of the Social Security Act (Act) states that “financial institution” has
the meaning given the term in section 469A(d)(1) of the Act. Section 469A(d)(1) of the Act
defines a “financial institution” as “a depository institution, as defined in Section 3(c) of the
Federal Deposit Insurance Act (12 U.S.C. 1813(c))…an institution-affiliated party, as defined in
section 3(u) of such Act (12 U.S.C. 1813(u))…any federal credit union or state credit union, as
defined in Section 101 of the Federal Credit Union Act (12 U.S.C. 1752), including an
institution-affiliated party of such a credit union, as defined in Section 206(r) of such Act (12
U.S.C. 1786(r))…and any benefit association, insurance company, safe deposit company,
money-market mutual fund, or similar entity authorized to do business in the state.”

1.2

Definition of Account

Section 466(a)(17)(D)(ii) of the Act defines an “account” as “a demand deposit account,
checking or negotiable withdrawal order account, savings account, time deposit account, or
money-market mutual fund account.”

1.3

Who May Match Data with OCSE?

Any financial institution operating in two or more states that maintains accounts (as defined in
section 466(a)(17)(D)(ii))) for its customers is eligible to participate in the OCSE data match.

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1.4

What Liability Will Accrue to Financial Institutions?

Section 466(a)(17)(C) of the Act states 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 child support
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 state child support enforcement agency. In
addition, financial institutions will not be held liable for other action taken in good faith to
comply with the requirements of Section 466(a)(17)(A) of the Act. Section 469A(a) of the Act
also provides protection from liability for MSFIs disclosing information to the FPLS through the
MSFIDM.

2

Data Match Process

The data match process begins when OCSE sends MSFIs a file containing information about
individuals who owe past-due child support. The MSFIs compare the OCSE file with their
account holders and return matches to OCSE. OCSE sends matches to the state agencies
responsible for collecting the past-due support. OCSE maintains and updates the file containing
all child support debtors nationwide weekly and transmits files to all participating MSFIs
quarterly. Processing quarters are standard calendar quarters: the first day of January, April, July,
and October.
To avoid processing peaks, MSFIs may select a preferred month and week to receive their file in
each quarter. For example, if an MSFI chooses to initiate processing of its file in the first week of
the second month of a quarter, it will subsequently receive all files the first week of the second
month of each calendar quarter thereafter.
MSFIs have 45 days to return matches to OCSE.

2.1

Data Specifications

We use a reporting format developed by states, MSFIs, and OCSE. OCSE uses Method 2 – the
Matched Accounts Method. You can find the record layout for this reporting format on the
OCSE website at https://www.acf.hhs.gov/sites/default/files/documents/ocse/
msfidm_specifications_handbook.pdf

2.2

Types of Transmission

OCSE exchanges data with MSFIs using electronic transmission methods, currently either
Secure File Transfer Protocol or OCSE’s Child Support Portal Electronic Download and Upload
Process. OCSE works with the MSFI to use the most cost-effective method for the data
transmission.

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2.3

What Happens When a Match Occurs?

OCSE forwards the match information to the states and territories within 48 hours. The states
and territories may use the match information to notify the MSFI to freeze or seize accounts in
accordance with state laws.

2.4

What about Fees?

OCSE does not reimburse MSFIs for the cost of processing the data matches. If state law allows,
state child support enforcement agencies may pay reasonable fees to financial institutions for
conducting the data match. These fees must not exceed the actual costs incurred by the financial
institution.
If an MSFI chooses to recover the cost of processing the OCSE data, the MSFI must bill
individual states. Following each quarterly match, OCSE supplies MSFIs with a statistical report
containing the number of matches made for each state and the states’ billing addresses. However,
OCSE will only supply addresses for states that will reimburse MSFIs.

2.5

Security Guidelines

OCSE requires robust security and privacy controls to make sure the information on the OCSE
file remains protected and that there is individual accountability in protecting and maintaining
the privacy of the individuals whose information resides in the file.
This section outlines the security requirements that an MSFI must have in place before receiving
the OCSE file.
The MSFI must:
•
•

•
•

•
•

•

Maintain an audit trail of activities pertaining to the OCSE file and its contents until
destroying it.
Destroy electronic files, regardless of the delivery medium, after conducting the data match,
but no longer than 60 days afterward. Deletion is not acceptable. You must overwrite the file
and save with nulls before erasing the file.
Do not make hard copies of the file.
Establish and maintain a security incident response capability. You must report all security or
privacy incidents, or suspected incidents, involving the file to OCSE no later than one hour
after discovery.
Implement logical access controls that supply protection from unauthorized access,
alteration, loss, or disclosure.
Limit physical and logical access to the OCSE file and the information contained within to
authorized personnel only. Make sure to maintain a list of the persons authorized to access
the information.
Prohibit downloading information on the OCSE file to portable media.

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•
•

Provide security awareness training to communicate the security policies associated with the
OCSE file as well as the civil and criminal penalties for misuse.
Secure the OCSE file during transmission in a manner that safeguards the data and prohibits
unauthorized access.

3

Data Match Timelines

3.1

Operational Agreements

•

OCSE distributes one operational agreement to each MSFI identified by states or other
sources. The agreement allows MSFIs to select their data transmission method and reporting
period dates and designate service providers if appropriate. The agreement also allows
MSFIs to opt out of the OCSE process in favor of participating with individual states.
Note: MSFIs only need to update agreements when they elect to change the
data transmission method or change a service provider.

•

MSFIs return agreements to OCSE.

3.2

Fee Assessment Information

On a quarterly basis, OCSE supplies:
•
•
•

MSFIs with the number of matches per state.
States with the number of matches for each MSFI.
MSFIs with a state-by-state description of the fee structure, fee amounts allowed, and billing
addresses for those states that will reimburse MSFIs for the data match.

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4

Election Form Instructions

The Election Form is on pages 6 and 7. When completed and signed by an officer or executive of
the MSFI, the Election Form will serve as the official operational agreement between the MSFI
and OCSE.

4.1

Due Date

The Election Form must be completed, signed, and returned to OCSE within 30 days of receipt,
even if the MSFI chooses not to participate.

4.2

Election to Participate

MSFIs may elect to participate in the OCSE match process by checking the appropriate box in
the Action Box on the Election Form and completing the form as directed.
MSFIs may also use the Election Form to choose not to participate in the OCSE process,
deciding instead to conduct the required quarterly match with all the states where they do
business. In these cases, MSFIs are still required to complete the Election Form and attach a list
of states where they do business. OCSE will notify the affected states of the decision.

4.3

Election to Use Reporting Agents

Many MSFIs contract with reporting agents for the MSFIDM program. If an MSFI chooses to
contract with a service provider to report information for the MSFIDM, the MSFI must sign the
Election Form, not the service provider, and the MSFI remains responsible for complying with
the law.
MSFIs that choose to use a reporting agent or transmitter must inform OCSE by completing the
appropriate section on the Election Form. Signing the Election Form allows OCSE to request and
receive MSFI contact information from the reporting agent or transmitter. Similarly, if an MSFI
wants OCSE to send the data match file to a recipient whose Federal Employer Identification
Number (FEIN) is different from that of the MSFI, the MSFI must notify OCSE.

4.4

Election Form

Mail, fax, or email your completed election form to:
Office of Child Support Enforcement
Multistate Financial Institution Data Match
PO Box 509
Baltimore, Maryland 21133-0509
For assistance call: 800-258-2736
Fax:
410-277-9325
Email: fidm@ssa.gov
Website: https://www.acf.hhs.gov/css/partners/financial-institutions

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OMB Control No: 0970-0196
Expiration Date: 01/31/2024

Election
Form

Office of Child Support Enforcement
PO Box 509
Baltimore, Maryland 21133-0509

Financial institutions must use this form to (1) elect to participate in the multistate financial data
match with the federal Office of Child Support Enforcement (OCSE) and select an electronic
data exchange option, or (2) elect not to participate in the OCSE process. Refer to the attached
instructions for more information. When completed and signed by an authorized representative
of your organization, this form will serve as the official operational agreement with OCSE.
Multistate Financial Institution (MSFI)
MSFI Name:*

FEIN:*
Phone:*
Fax:
Email:*

Contact:*
Street Address:*

Mailing Address (if different
from street address):

Action (New elections must attach a list of states and territories where you do business*)
Elect not to participate in OCSE process.
Elect to participate in the OCSE process. You authorize OCSE to disclose matched
information to any state IV-D agency that submitted debtors to OCSE.
Add or change transmitter or change file exchange option.
File Exchange Options
OCSE’s Child Support Portal Electronic Download and Upload Process
Secure File Transfer Protocol (SFTP)
Dates
Select the preferred month and week for the initial receipt of OCSE files.
Name one month:*

______________

Select one week:*

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1

2

3

4

Transmitter Information
If you plan to use a transmitter to exchange data with OCSE, please supply the following
information about your transmitter:
Name:

FEIN:

Street Address:

Contact:

Phone:
Fax:
Email:
Do you want the data match file sent directly to your authorized transmitter?

Yes

No

Authorized Representative *
Name (please print):
Signature:

Title:
Date:

Section 466(a)(17)(C) of the Social Security Act provides that a financial institution shall not be liable
under any state or state law to any person for any disclosure of information to the Child Support
Enforcement Agency under section 466(a)(17)(A)(i) of the Act. Similarly, financial institutions shall not
be liable under any state or state law for encumbering or surrendering any assets they hold in response to
a notice of lien or levy issued by the Child Support Enforcement Agency. In addition, 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.
In accordance with section 453 of the Social Security Act, the information provided to multistate financial
institutions (or their designated agents) for purposes of conducting the data matches may not be used by
such institutions or agents for any other purposes and may not be redisclosed to any person except to the
extent necessary to conduct the data matches. There may also be additional prohibitions or penalties,
which apply under state law.
A financial institution’s election to participate in the OCSE multistate financial institution data match
shall not be construed as a general waiver of jurisdiction nor will it be construed as consent to participate
in any other centralized data process.
This provision is not intended to prohibit a state from requiring any financial institution doing business in
the state to report account information directly to the state for purposes other than child support
enforcement.

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