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Minnesota Financial Institution Data Match


How will the expense reimbursements be paid to the financial institutions?

What method will be used to make these payments?

What information will be supplied with the levy payment?

If a financial institution has any overdraft charges or for example, a car loan outstanding with the tax debtor whose account is matched and the levy is served on their account, can the bank offset the loan or overdraft charges that are owed to the bank before sending the levied funds to MN Revenue?

Related to the previous question, what if a tax debtor has a CD that has funds held as collateral for a loan through the financial institution is the CD subject to levy also?

What if a bank has a perfected security interest on a CD, is that exempt from a levy?

What types of accounts are subject to the data match program?

What financial institutions must participate in the data match program?

What is the methodology of performing the data match?

How does Method One, the All Account Method, work?

How does Method Two, the Matched Accounts Method, work?

How often must the data match be conducted?

What data is returned to MN DOR’s Collection Division for use in collecting delinquent tax debts?

Can a financial institution be held liable for the release of account information relating to the Minnesota Financial Institution Data Match program and the levies that may result?

Will the Minnesota financial institutions receive a fee for conducting the data match?

Are IRA accounts eligible for levy under the financial institution data match program?

As a follow up to that, who is responsible for the tax liabilities?

Should safe deposit box account information be included in the data match file?


How will the expense reimbursements be paid to the financial institutions?

The Minnesota Department of Revenue, Collection Division will pay the financial institutions up to $150 per calendar quarter to defray costs borne by Financial Institutions in their efforts to participate in the program. Unlike the program administered by the Minnesota Department of Human Services, there is no payments or reimbursement to Financial Institutions for levies issued by Revenue that result from account matches obtained by DOR through this program.

What method will be used to make these payments?

The State will issue one payment per quarter. Whether the payment is made in the form of a paper check or is conveyed via EFT will depend on how the Financial Institution is registered as a vendor with the Minnesota Department of Finance.

What information will be supplied with the levy payment?

Payments made via paper check will have a memo on the stub "FIDM REIMBURSEMNT QUARTER YEAR" Further itemization is not possible because of privacy restrictions.


If a financial institution has any overdraft charges or for example, a car loan outstanding with the tax debtor whose account is matched and the levy is served on their account, can the bank offset the loan or overdraft charges that are owed to the bank before sending the levied funds to MN Revenue?

A financial institution can offset the loan or overdraft charges, if the account is security for such charges. For example, if an individual has a savings account that is security for a loan, only the funds in excess of that security should be seized.

However, if an individual has two accounts, one being a checking account that has an overdrawn charge and one being a savings account, the financial institution cannot use funds from one account to pay the other account unless that other account has previously been identified as security for the overdrawn account.

And if an individual has a loan which is delinquent AND another account, such as a savings account, the financial institution cannot hold back funds to pay the loan unless the account was previously identified as security for that account or the financial institution has already taken the appropriate action to satisfy the delinquent loan with those funds.


Related to the previous question, what if a tax debtor has a CD that has funds held as collateral for a loan through the financial institution is the CD subject to levy also?

The amounts in excess of the security are subject to the levy.


What if a bank has a perfected security interest on a CD, is that exempt from a levy?

The same exemptions that apply to other levy actions also apply to these levy actions.


What types of accounts are subject to the data match program?

  • Demand deposit accounts
  • Checking accounts or negotiable withdrawal order accounts
  • Savings accounts
  • Time deposit accounts
  • Money-market mutual fund accounts

What financial institutions must participate in the data match program?

  • Bank and savings and loans
  • Federal and State credit unions
  • Money market mutual funds

What is the methodology of performing the data match?

There are two reporting methods for financial institutions: Method One (the all accounts method) and Method Two (the matched accounts method)


How does Method One, the All Account Method, work?

  • Financial institutions submit a file identifying all open accounts to DOR via its vendor, PSI.
  • The MN DOR’s Collection Division conducts an internal match against tax debtors.
  • The collection division may issue levies to attach and seize the asset(s) of the tax debtor.

How does Method Two, the Matched Accounts Method, work?

  • MN DOR’s Collection Division submits an inquiry file, containing tax debtors, to the financial institution.
  • The financial institution conducts an internal match against its open accounts.
  • The financial institution sends a file to the MN DOR Collection Division that reports information on all accounts maintained by individuals on the inquiry file.
  • The match report must be returned to the State within 30-45 days of receipt of the inquiry file.
  • MN DOR’s Collection division may issue levies to attach and seize the asset(s) of the matched tax debtors

How often must the data match be conducted?

It must be performed quarterly.


What data is returned to MN DOR’s Collection Division for use in collecting delinquent tax debts?

Financial institutions are required to provide the name, record address, Social Security number or other taxpayer identification number, and other identifying information for each match. Account balances are not required. The inclusion of this information will, however, significantly reduce the likelihood of the Collection Division issuing levies against accounts with small balances. Recall, from above that DOR does not reimburse or make payments to Financial Intuitions on a per levy issued basis.


Can a financial institution be held liable for the release of account information relating to the Minnesota Financial Institution Data Match program and the levies that may result?

No, Minnesota State Statute 13B.07 Subdivisions 9 and 10 established that a financial institution shall not be liable under state law to any person for any disclosure of information to the Commissioner of Revenue. Moreover, Financial Institutions are prohibited from disclosing to a tax debtor that his/her name has been received from or furnished to DOR.

Financial institutions will not be held liable for any other action taken in good faith to comply with the requirements of FIDM.


Will the Minnesota financial institutions receive a fee for conducting the data match?

In accordance with Minnesota Statute 13B.07, subdivision 7, a financial institution may charge and collect a fee from DOR for providing account information. The DOR may pay a financial institution up to $150.00 each quarter if the Department and the financial institution have entered into a signed agreement that complies with provisions of the program.

Payment of the fee is limited by the amount of the appropriation for this purpose. If the appropriation is insufficient, or if fund availability in the fourth quarter would allow payments for actual costs in excess of $150.00 per quarter, the Department will prorate the available funds among the financial institutions that have submitted a claim for the fee.


Are IRA accounts eligible for levy under the financial institution data match program?

Yes, All 401K, 403B, KEOGH, IRA's etc. are eligible for levy as long as the person/employee (privately, publicly or self-employed) is the one who controls the account, i.e. can decide to take money out of the account.


As a follow up to that, who is responsible for the tax liabilities?

The account holder is responsible for all tax liabilities resulting from the early withdrawal of funds due to a financial institution data match levy.


Should safe deposit box account information be included in the data match file?

No, this information should not be included. The contents of safe deposit boxes are not subject to levy.




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