No, your bank is not required to enter into this new agreement with DHFS, which authorizes multistate child support data sharing, although we believe most Illinois banks will do so.

Federal and Illinois law require financial institutions to share customer data under written agreements with the DHFS, which uses this data to “match” responsible relatives who owe past-due child support. Previously, the DHFS did not share Illinois data with other states, although many multistate financial institutions already do share their data across state lines through the federal Office of Child Support Enforcement data match program (which was created for this purpose in federal law). However, the DHFS wishes to expand the Illinois data match program for unpaid child support to nineteen other states that utilize the same third-party vendor as Illinois for administering the program.

To participate in Illinois’ new multistate data matching process, financial institutions may — but are not required —  to enter into a new DHFS agreement to expressly permit sharing data with other state agencies. If your bank chooses to engage in multistate data matching with DHFS, your core processor will continue to submit data to DHFS exactly as it did before. Only now, DHFS will share the data with other states on a reciprocal basis.

For more information, see the Data Matching Resources page on GoToIBA.com.

For resources related to our guidance, please see:

• Illinois Public Aid Code, Financial Institution Data Match Program, 305 ILCS 5/10-24.5(a)  (“The Illinois Department may design and implement a data match system pursuant to which the Illinois Department shall enter into agreements with financial institutions doing business in this State for the purpose of identifying accounts as defined in Section 10-24 of responsible relatives who owe past-due child support.”)