Skip Navigation Links

PA Child Support Program

Frequently Asked Questions

 FIDM FAQ

Last modified on: October 28, 2010

FIDM Overview
1. What is the purpose of the Financial Institution Data Match (FIDM) Program?
The purpose of FIDM is to identify financial assets belonging to delinquent child support obligors. Once identified, these assets may be frozen and seized by the Domestic Relations Section of the County Court of Common Pleas.
2. What is the definition of Financial Institution according to Pennsylvania law?
  • A depository institution, as defined by section 3(c) of the Federal Deposit Insurance Act (64 Stat.873, 12 U.S.C 1813(c));
  • An institution-affiliated party, as defined by section 3(u) of the Federal Deposit Insurance Act;
  • A Federal Credit union or State credit union, as defined in section 101 of the Federal Credit Union Act (48 Stat. 1216, 12 U.S.C 1752), including an institution-affiliated party of such a credit union, as defined in section 206(r) of the Federal Credit Union Act;
  • A benefit association, insurer, safe deposit company, money market mutual fund or similar entity authorized to do business in this commonwealth.

Title 23 of Pennsylvania Consolidated Statutes Annotated (Pa. C.S.A.) §4304.1(g) defines "financial institution" as follows:

  • A depository institution, as defined by section 3(c) of the Federal Deposit Insurance Act (64 Stat.873, 12 U.S.C 1813(c));
  • An institution-affiliated party, as defined by section 3(u) of the Federal Deposit Insurance Act;
  • A Federal Credit union or State credit union, as defined in section 101 of the Federal Credit Union Act (48 Stat. 1216, 12 U.S.C 1752), including an institution-affiliated party of such a credit union, as defined in section 206(r) of the Federal Credit Union Act; and
  • A benefit association, insurer, safe deposit company, money market mutual fund or similar entity authorized to do business in this commonwealth.
3. What is the definition of "account" according to Pennsylvania Law?
23 Pa.C.S. §4304.1(g) defines "accounts" as follows:

  • A demand deposit account, checking or negotiable withdrawal order account, savings account, time deposit account, or money market mutual fund account.
  • The term does not include trust accounts, custodian accounts, or accounts under 20 Pa.C.S. Ch. 53 (relating to the Pennsylvania Uniform Transfers to Minors Act).
4. What is the Multistate Financial Institution Data Match (MSFIDM) Program?
The Federal Office of Child Support Enforcement (OCSE) assists states in conducting data matches with Multistate Financial Institutions (MSFI). A MSFI is defined as a Financial Institution operating (i.e. has offices - brick & mortar) in two or more states. If a bank or credit union has physical locations in two or more states it is then up to that particular Financial Institution's legal/compliance division to determine whether the Financial Institution will participate as a MSFI, matching accounts against a national file of delinquent obligors, or as an in-state FI, matching accounts against each state's file of delinquent obligors. Additional information regarding the MSFIDM program can be found at: http://www.acf.hhs.gov/programs/cse/fct/fidm/
5. What requirements exist for safeguarding information?
In accordance with 23 Pa.C.S. §4304.1(d), any person, government agency, employer or agent of DPW who divulges such information in a manner not provided by law commits a misdemeanor of the third degree and, upon conviction, shall be sentenced to pay a fine of up to $1000 per violation and costs and shall be subject to a term of imprisonment of not more than one year, or both. In the FIDM agreement, DPW and the Financial Institution agree to take all reasonable steps to ensure that their employees and agents keep this information confidential. Any information obtained from a Financial Institution is considered confidential and is not public record. Each person or government entity that obtains account information from a Financial Institution is prohibited from disclosing the information for any purpose other than the establishment, modification or enforcement of a support order. Employees of the PA FIDM Program are required to sign the PA FIDM Confidentiality Certification Form prior to the handling of confidential data. The Confidentiality Form explains the laws governing the use of the data obtained under the PA FIDM Program as well as alerts the employee that he or she may be terminated and/or subject to fines or imprisonment for the misuse or release of the data.

6. Are Financial Institutions exempt from liability for providing information?
Yes. In accordance with Federal and State laws, a Financial Institution and its officers, directors and employees are exempt from criminal or civil liability for disclosing or releasing account information to a child support enforcement agency, or for any other action the Financial Institution takes in good faith to meet the data match requirements.
To our knowledge there have been no successful lawsuits filed against a Financial Institution by an account owner for providing information under the PA FIDM program.
7. What are the differences between the Federal Program and the Pennsylvania Program?
The PA FIDM Program is using the Federal File Specifications Handbook that may have been sent in a mailing to your organization. However, there are program differences between the Federal Program and the PA Program. For example:

  • PA Law requires the reporting of account balance.
  • PA does not accept account update files. Each data exchange must be a complete file.
  • PA does not accept 1099 layout files.
  • PA does not accept files that span multiple media. The header, detail, and trailer records must be able to fit on one media; therefore, Financial Institutions should select a media type that will be able to hold an entire file.
  • Each media type must contain only one file.
8. Can I match under Method One if my institution has over $25 million in assets and over 100 accounts?
No. Unfortunately, the Governor's Policy Office has determined that no waivers can be granted under these circumstances.
Financial Institutions Topics
1. Our company does not meet the definition of Financial Institution and/or hold the types of accounts as defined by Pennsylvania law. Is there an exemption process?
Yes. If you believe your company should not be required to participate in the PA FIDM Program, please send an exemption request with the following information:

  • Company Name and FEIN (Federal Employer Identification Number).
  • Contact Name and Phone Number.
  • Reason for claiming exemption.

To send exemption requests, please use the BCSE Mailing Address
2. Our Financial Institution participates in the MSFIDM Program with OCSE. Are we also required to participate in the Pennsylvania FIDM Program?
No. As referenced in the PA FIDM Agreement, if your Financial Institution operates in several states and has chosen to participate in the OCSE's MSFIDM Program, your Financial Institution is not required to participate in the PA FIDM Program. In lieu of completing the Pennsylvania FIDM Agreement, please provide the PA FIDM Program a copy of your Financial Institution's agreement with the OCSE to participate in the MSFIDM Program.

To send MSFIDM agreements, please use the BCSE Mailing Address.
3. How does my Financial Institution change information indicated on the FIDM Agreement?

Contact and Address Information changes can be accomplished by completing the Address/Contact Information Change Request form, or by submitting a written request to the BCSE Mailing Address.

Match Method and Media changes can be accomplished by completing the Contact Data and Program Option Sheet and submitting the request in writing to the BCSE mailing address.

Financial Institution name changes or Federal Employer Identification Number changes must be accomplished by completing a new Financial Institution Data Match Agreement. To request a new FIDM Agreement form, please contact BCSE.

4. Is an account exempt from being reported if the obligor is the trustee on the account and considered the owner?
A true trust account is exempt from lien/levy. The only exception is a "totten" trust where the obligor has full beneficial ownership.

5. Is a Spend Thrift Trust account exempt from seizure through the PA FIDM Program?
No. A Spend Thrift Trust account can be attached for overdue support amounts. Superior Court Case, Drevenik v. Nardone, 862 A.2d 635(Pa. Super.,2004), established that a Spend Thrift Trust can be ordered to pay full payment of the accrued arrears and/or ordered to pay a percentage of the trustee's income thereafter as current support.

6. Is a business account exempt if the obligor is a signatory of the account or the sole proprietor of the business?
If the account is a sole proprietorship/partnership a PA FIDM freeze/seize may be used on the assets. An account that is a corporation or the obligor has signature authority only, does not come under the PA FIDM process

7. If a company is a holding company for two banks what requirement(s) is that company under in the in-state PA FIDM Program?
A holding company by definition will not have account holders, but the banks under the holding company are required to report.

8. Are accounts held by a Financial Institution for an obligor as collateral for any and all debt owing, available for attachment?
If there is a debt outstanding and the security cannot be withdrawn by the obligor to the extent of the debt, the funds are deemed not "available" in the account for attachment. However, funds exceeding the balance owed on the debt are available for seizure.

9. Are Financial Institutions, participating in the PA FIDM Program, allowed to charge a fee against the obligor's account for the processing of the lien?
Yes. Title IV-D law governing the PA FIDM Program does not prohibit a Financial Institution from charging the account holder a fee for processing a PA FIDM lien. The fee should not be subtracted from the amount to be encumbered per the court order, but may be subtracted from assets available prior to applying the encumbrance.

10. Are IRA's and pension accounts included?
Title 26 of the United States Code (26 U.S.C.) §408(a) defines an IRA as "a trust". It is the Department of Public Welfare's policy that IRA accounts are not subject to seizure through the PA FIDM Program. Such accounts should be reported in the quarterly match of assets through the PA FIDM Program and then attached for child support enforcement purposes by a Qualified Domestic Relations Order (QUADRO). Under the QUADRO exception, a domestic relations order may assign some or all of the participant's pension benefits to a spouse, former spouse, child, or other dependent to satisfy family support or marital property obligations if, and only if, the order is a "Qualified Domestic Relations Order."

11. What about mortgage escrow accounts?
Mortgage escrow accounts are reported. For Method One-Step, Method One Pre-Step Two, and Method Two, a mortgage escrow account is indicated in position 359 of the detail ("B") record by entering the numeral 3. For additional information, please refer to the file specifications as follows:

  • Method One One-Step: pages 8 and 9
  • Method One Pre-Step Step Two: pages 8 and 9
  • Method Two: pages 14 and 16

12. Are loan accounts reported to PA FIDM?
No. The PA FIDM Program is intended to identify assets. Because a loan account is a liability, these accounts are not reported.

FIDM Process Questions
1. Can Financial Institutions be reimbursed for costs related to the Financial Institution data match?
DPW may reimburse a Financial Institution that selects Match Method 2 for costs directly related to the quarterly match of the DPW support obligor file against account records maintained by the Financial Institution. The payment of fees shall be based upon auditable, actual, and reasonable costs not to exceed $250 per quarter.

Reimbursement of match costs will be based on the exchange of an obligor name and Social Security number, not the number of accounts owned by the obligor at the Financial Institution. DPW will only authorize payment of the actual costs incurred by the Financial Institution at an amount not to exceed the rate of reimbursement specified above. Financial Institutions will not be reimbursed for data processing setup costs.

With each reimbursement request, the Financial Institution must provide a detailed description of the methodology used by the Financial Institution to establish match costs. The methodology must document that costs used by the Financial Institution do not exceed rates charged for similar services in the financial industry. Examples of the methodology may include an invoice from a third party data processor showing costs charged to the FI or a number of hours times the cost per hour for that person.
2. When is the invoice due to FIDM?
All requests for reimbursement are due to the PA FIDM Program within 30 days following the file submission deadline for each quarter. Upon receipt of a properly documented claim for reimbursement the PA FIDM Program and DPW will verify:

  • the adequacy of the cost methodology;
  • the successful processing of the data match; and
  • the invoice's conformity with the submitted cost methodology.

After verifying the invoice the PA FIDM Program will forward the invoice to the DPW for payment.
3. Can I submit my own invoice?
No.Reimbursement requests must be submitted on the invoice provided by DPW. Financial Institutions selecting Match Method 2 will receive the invoice with a copy of their signed agreement from the DPW.
4. When can I expect my payment?
Financial Institutions can expect a payment approximately 60-90 days following the request for reimbursement.
5. What is the service period on the Invoice Form?
The service period on the General Invoice 10-2003 form is the beginning and ending date for the quarter in which your Financial Institution reported.
6. My invoice was rejected. Why?
There are several reasons an invoice may be rejected. The Rejection Notice sent by PA FIDM lists the reason(s) for rejection. Our most common invoicing issues are:

  • File not yet submitted for the quarter
  • Unsuccessful data match in the quarter
  • File was late
  • Incomplete invoice information
  • Invoice Form was not used
  • Invoice was not signed
  • Invoice was late

If you have questions about your Rejection Notice, please contact the PA FIDM Coordinator at (717) 783-8557.
7. When will the testing process occur?
The PA FIDM Program does not require testing. Upon execution of your Agreement, the PA FIDM Program will contact your Financial Institution with a request to initiate the quarterly match. Once you submit your Method One (One Step and Pre-Step) or Method Two file, it is processed immediately. If the file process is successful, your work is done for the quarter. If there is a problem with your file, you will be contacted and the PA FIDM Project Manager will work with you or your service provider/software vendor to correct the problem.
8. Our Financial Institution is unable to meet the initial file submission date. Will the PA FIDM Program grant extensions?
Financial Institutions must submit a written request to the PA FIDM Program stating why an extension is necessary. The PA FIDM Program will forward extension requests to the Department of Public Welfare (DPW) for review. DPW will review the requests and notify the Financial Institution of their decision.
To send extension requests, please use the BCSE mailing address.
9. When will I receive my manual template for processing?
Financial Institutions that have selected Method One, manual processing, will receive a template with the return of their signed FIDM Agreement.
10. I don't understand the file specifications and I don't know how to create a file. What should I do?
PA FIDM does not endorse any specific vendor or software application to conduct the quarterly data match. However, several options are available. It is recommended that you receive guidance from your professional association.
11. I'm a third-party Data Processor representing more than one Financial Institution in Pennsylvania. Can I put more than one Financial Institution on the same media?
You may report for all of your Financial Institutions on the same media provided that you meet the following conditions:

  • Each piece of media must contain one complete file.
  • Each Financial Institution includes both a header record and a trailer record.
  • The entire file fits on one media.

12. My file is too large for one floppy disk. Can I use two floppy disks?
No. The file must fit on one media. PA FIDM does not support files spanning media. PA FIDM does support zip files, which may eliminate this issue. Financial Institutions may also choose to send different media types to accommodate file size in each quarter.
13. My vendor is already reporting under the Federal Multistate Financial Institution Data Match Program. Can we use the same software?
If the software is compliant with the Federal Financial Data Match Specifications Handbook, dated October 25, 2004, you may use the same software.
The file layout can be found on the Internet at:
http://www.acf.hhs.gov/programs/cse/fct/fidm/