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Rules and Regulations: The Financial Institution Record Match (FIRM) Program

In January, 2012, the Franchise Tax Board (FTB) began its systematic roll-out of the Financial Institution Record Match (FIRM) program. This program exists to authorize financial institutions (including banks, credit unions, insurance and brokerage companies) located in California to assist the FTB in matching the files of “debtors” in the Franchise Tax Board’s system against the accounts at their institutions.


The Financial Institution Record Match (FIRM) Program identifies delinquent debtor accounts through a record match process. FIRM is an enforcement tool used to collect delinquent taxes and non-tax debts of individuals and business entities.

Coupled with FIRM is a second program called the FIDM (Financial Institution Data Match). Here, financial institutions compare their files with the State Child Support programs and conduct data matches to identify accounts of those who are delinquent on their child support.


Each quarter we upload a file to a state contracted company that runs our data against the list of individuals or entities who owe state taxes or other things the FTB is in charge of. If there are matches then we would move forward with a request for funds in the form of a garnishment from those individuals or entities.


If you have questions about the FIRM program, FTB or how we comply with these programs, please contact Chris Van Sickle, our Compliance Officer at, or by mail at our California Street address.

Rules and Regulations: Protecting Members from Elder Financial Abuse

In the “Rules and Regulations” series, we’re hoping to inform members of the regulatory reporting that we’re required to follow in order to comply with banking regulations. This article, we’re addressing elder financial abuse.

What is elder abuse?

When we talk about elder abuse as it relates to the credit union, we are referring to the financial abuse of an elder (any person residing in California who is 65 years of age or older) or dependent adult (anyone between the ages of 18 and 64 who has physical or mental limitations that restrict their ability to carry out normal activities or to protect their rights). Financial abuse is generally the taking of real or personal property for wrongful use, or assisting in doing so.

Unfortunately, the perpetrators most often include family members, specifically spouses, children or grandchildren. Other perpetrators may include individuals who seek out vulnerable seniors with the intent of exploiting them.