Privacy Act of 1974: EXIM Bank Financial Management System-Next Generation System of Records Update
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
The Export-Import Bank of the United States (EXIM Bank) is updating its System of Records Notice (SORN) under the Privacy Act of 1974 for its Financial Management System-Next Generation (FMS-NG). This system handles core banking and financial operations including accounting, fund disbursement, loan and guarantee servicing, and financial reporting. The system collects and maintains sensitive personal and corporate data including customer names, U.S. and foreign addresses, bank account information, Employer Identification Numbers (EINs), and banking routing numbers. The update aligns the system's routine uses with OMB Memorandum M-25-32, titled 'Preventing Improper Payments and Protecting Privacy through the Do Not Pay,' issued on August 20, 2025. The primary driver of this update is compliance with the new OMB directive requiring federal agencies to use the Do Not Pay (DNP) system to cross-check recipients before disbursing funds. This is intended to reduce improper payments to ineligible entities while ensuring privacy protections are maintained for the personal data held within FMS-NG.
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Key Changes
- EXIM Bank updates its SORN for the Financial Management System-Next Generation (FMS-NG) to comply with OMB Memorandum M-25-32 issued August 20, 2025
- Routine uses of the FMS-NG system are expanded to allow data sharing with the Do Not Pay (DNP) system for payment eligibility verification
- Personal data fields now explicitly covered include: customer name, U.S. and foreign addresses, EIN, bank account numbers, and banking routing numbers
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Obligations
What this law requires
EXIM Bank must update its System of Records Notice (SORN) for the Financial Management System-Next Generation to align routine uses with OMB Memorandum M-25-32 requirements
EXIM Bank must use the Do Not Pay (DNP) system to cross-check recipients before disbursing funds to reduce improper payments to ineligible entities
EXIM Bank must maintain privacy protections for personal data held within the Financial Management System-Next Generation when implementing DNP compliance requirements
EXIM Bank must ensure the updated SORN for FMS-NG complies with the Privacy Act of 1974 requirements