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News Archive

Compliance Compass: wait before agreeing to data match


Paul Guttormsson,
League Legal Counsel

Recently, the Wisconsin Department of Workforce Development (DWD) sent credit unions and other financial institutions in the state a service agreement regarding its new Unemployment Insurance Financial Record Match Program.


At this time, The League recommends that credit unions wait to sign the agreement because of some concerns we have over its terms.


The agreement asks credit unions to choose whether they will receive information from the state quarterly and match that information against the credit union’s records (the "financial institution matching option") or submit information about account holders to the state so that it can conduct the matches (the "state match option").


The agreement goes on to require all participants to develop a state-approved corrective action plan to follow if confidential unemployment insurance information is misused or stolen. It also permits the DWD to conduct a compliance review of the credit union’s security procedures to protect confidential information. The provisions seem overly broad and unnecessary for credit unions that choose the state match option.


The League has been in contact with other stakeholder groups, which share our concerns and have similarly advised their institutions to wait before signing the agreement. We plan to pursue the issue further with the DWD directly, and we will alert credit unions regarding the status of the agreement.


The new program is similar to existing Wisconsin data match programs related to child support, delinquent taxes, Medicare and Medicaid programs, as explained in ii Release No. 0151—except that agreements for those programs did not raise similar concerns. These new developments have no impact on those other data match programs.


Questions? Contact me at (262) 408-6009.

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