Topic: Data Matching
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We received a letter from the Illinois Department of Healthcare and Family Services (DHFS) requesting that we sign a new Financial Institution Data Match Agreement. The letter indicates that “because you have not entered into the Agreement, your service processor is unable to transmit data encompassed by the new Agreement for any institution that utilizes the same service processor.” Are we required to sign this agreement? We don’t want to share personal information if we don’t have to.
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No, your bank is not required to sign the amended agreement with DHFS that authorizes the sharing of unpaid child support information on a multistate basis, although we believe that most Illinois banks will do or already have done so. Both federal and Illinois law require financial institutions to share certain data on Illinois customers…
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If we sign the updated agreement from the Illinois Department of Healthcare and Family Services (DHFS) regarding Financial Institution Data Match (FIDM) for unpaid child support, and we lien an account held in another state, do we need to be aware of the laws of that state?
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No, a bank that operates exclusively in Illinois does not need to be knowledgeable of other states’ laws to participate in multistate data matching for unpaid child support. The newly amended DHFS agreement for FIDM services does not require financial institutions to impose in-state or out-of-state liens; it only calls for them to provide data…
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Since participation in multistate data matching for unpaid child support is voluntary for in-state financial institutions, could our bank suffer any repercussions related to privacy breaches or BSA concerns if it chooses to participate?
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No, we do not believe your bank would suffer any negative repercussions by choosing to participate in multistate data matching for unpaid child support. Federal and Illinois law require financial institutions to share customer data under written agreements with the Illinois Department of Healthcare and Family Services (DHFS), which uses this data to “match” responsible…
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We have received an updated agreement from the Illinois Department of Healthcare and Family Services (DHFS) regarding Financial Institution Data Match (FIDM) services. Are we required to enter into this new agreement?
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No, your bank is not required to enter into this new agreement with DHFS, which authorizes the sharing of unpaid child support information on a multistate basis, 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…
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We have received an updated agreement from the Illinois Department of Healthcare and Family Services (DHFS) regarding Financial Institution Data Match (FIDM) services. Are we required to enter into this new agreement? Are there any privacy or liability issues with participating in the data match? Currently, our core processor conducts the data matches and sends the information to the DHFS.
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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…
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We have received an updated agreement from the Illinois Department of Healthcare and Family Services (DHFS) regarding Financial Institution Data Match (FIDM) services. Are we required to enter into this new agreement? Our core processor prepares and submits our current FIDM file to DHFS. Do we need to follow up with them regarding this new agreement?
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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…
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What should we be doing with the quarterly child support reports we receive from our processor?
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The Illinois Public Aid Code requires all financial institutions to enter into agreements with the Illinois Department of Healthcare and Family Services (DHFS) regarding child support data matching. These agreements require the financial institution to provide information to help DHFS locate deposit accounts in order to satisfy past-due child support obligations of non-custodial responsible relatives.…
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Can we exercise a right of offset in a customer’s deposit account after receiving a notice of lien from the Illinois Department of Healthcare and Family Services (IHFS)?
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If your bank had a right of set-off prior to the IHFS lien, your bank’s right of set-off would trump the IHFS lien. The Illinois Public Aid Code makes such liens (for past-due child support) subordinate to a bank’s prior rights of set-off: “(h) A lien created under this Section is subordinate to . .…