Compliance Compass: wait before agreeing to
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 agreementbecause 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.