Foreign Account Tax Compliance Act

Foreign Account Tax Compliance Act
Overview
FATCA is a tax law designed at preventing US tax payers from evading US Tax by holding income-producing assets through accounts at Foreign
Financial Institutions (FFIs).
FATCA brings about a significant change to the rules governing cross-border payments and will have far reaching consequences.
Under FATCA, financial institutions must sign an agreement with the IRS to be designated as a “participating foreign financial institution" or
PFFI. The FFIs will be required to identify US accounts and report about these accounts to IRS on an annual basis. Besides, US financial insti-
tutions (USFIs) and FFIs must report certain information to the IRS about substantial US owners of non-financial foreign entities (NFFEs).
Five countries – United Kingdom, Germany, Italy, Spain and France – are currently covered under the Inter Governmental approach (IGA). The
FFIs in these countries will have to enter into an agreement only with their local regulators instead of the IRS and report to them on an annual
basis. The regulator will in turn report the information to US (this is mostly on a reciprocal basis). Although, IGA is applicable only to five
countries as of now, it is expected that many countries (both EU and non-EU) will become FATCA partners under IGA.
Withholding taxes (30%) will apply to specified US source income (dividend, interest payments and the gross sale proceeds resulting from sale
of assets that give rise to US source income) in case of payments made to non-participating FFIs, recalcitrant account holders or NFFEs that
have not provided information regarding its substantial owners.If the foreign institution is a PFFI, the U.S paying agent will not have to with-
hold the payment but the PFFI would have to apply the withholding to its investors – both US and non US persons – if they are not in com-
pliance with requirements of FATCA.
Foreign Account Tax Compliance Act - Release R13.00 -Page 2 of 69 - (c) Temenos Systems 2013 27/06/2013
Prerequisites
The following contains a list of prerequisites for this Module.
Component
FA module has been installed, for installing a new module please refer to the "Installing a new Product User Guide"
Abbreviations
The following abbreviations are used within this document;
Abbreviation Description
FATCA Foreign Account Tax Compliance Act
FFI Foreign Financial Institution
USFI US Foreign Institution
NFFE Non Financial Foreign Entity
PFFE Participating Financial Foreign Entity
Financial Institutions
FATCA defines financial institutions as entities that:
l Accept deposits in the ordinary course of a banking business (includes savings banks, commercial banks, thrifts, credit unions and
other cooperative banking institutions)
l Hold financial assets for the accounts of others as a substantial part of their business (broker-dealers, trusts and custodial banks)
l Are engaged in the business of investing, reinvesting or trading (mutual funds, hedge funds and other managed funds)
By this definition, it is clear that FATCA will have a direct impact on FFIs that have US proprietary investments, US account holders or US fin-
ancial dealings.
Generally speaking, an FFI Agreement requires;
l A determination of which accounts are “United States accounts” (a defined term),

l Compliance with verification and due diligence procedures,
l Annual reporting on those United States accounts to the US Treasury (except for institutions in countries covered under the IGA),
l Compliance with additional IRS reporting requests, and withholding 30% where applicable (e.g., recalcitrant account holders, non-par-
ticipating FFIs, etc.)
In the case of accounts held by entities, rather than individuals, PFFIs must have the information (substantial ownership) to determine
whether the accounts are;
l to be treated as US accounts
l or accounts of participating FFIs
l or accounts of deemed-compliant FFIs
l or accounts of non-participating FFIs
l or accounts of exempt FFI
l or accounts of recalcitrant account holders, etc
It is also necessary for any US withholding agent to make similar determinations with respect to the recipients of the relevant payments
Recalcitrant Accounts
A recalcitrant account holder is 1) an account holder who fails to comply with reasonable requests for information pursuant to IRS mandated
verification and due diligence procedures for identifying US accounts or 2) an entity that fails to provide details such as names, addresses and
TIN of substantial owners and 3) one who fails to provide the necessary waivers upon request.
US Accounts
A “US account” is a financial account held by one or more specified US persons or a “US owned” foreign entity. Under the new law, a specified
US person is any US person other than any of the following:
l Any corporation the stock of which is regularly traded in an established securities market
l Any corporation that is part of the same expanded affiliated group as a public corporation
l Any tax-exempt organization
l Any bank
l Any real-estate investment trust
l Any state owned agency
l Any trust that is exempt from tax
l Any regulated investment company
FFIs must institute procedures to determine if the account holder is a US citizen or holds a US green card or plans on spending 183 or more
days in the US in the current year or has spent 183 days or more in the US in any of the proceeding three years or has spent 121 days or more in
the US in any of the preceding three years.
NFFEs can avoid imposition of 30% withholding tax if the entity provides the withholding agent with necessary documentation to the effect
that it does not have substantial US owners or provides the withholding agent with the name, address and TIN of each US substantial owner.
Wha t is a U S Subs ta ntia l owne r ?

The term US “substantial owner” refers to the following:
l Any corporation, any specified US person that owns, directly or indirectly, more than 10% of the stock of such corporation
l Any partnership, any specified US person that owns, directly or indirectly, more than 10% of the profits or capital interest in such part-
nership
l Any trust, any specified US person treated as an owner of any portion of such trust
Major areas of impact
The major areas of impact as far as FATCA is concerned are:
Currently the T24 solution addresses only the client identification (customer categorization) requirements.
Indicia of US Status
A PFFI must treat financial accounts held by specified US persons or US owned foreign entities as “US” accounts and report or withhold on
such accounts. The new regulation lists seven indicia of US status:
l Account holder is a US citizen or resident

l Account holder has a US place of birth
l Account holder has a US Telephone Number
l Account holder has a US mailing or permanent address
l An account where the only address is an “in care of” address; “hold mail” address or a US P.O. Box
l An account that has POA granted to a person with US address
l An account that has instructions to send payments to an account in US
The accounts that have one of these indicia will have to be subject to closer scrutiny to determine whether it belongs to a US person.
A participating FFI will have to put in place customer on-boarding and account opening procedures to identify US accounts opened on or after
the effective date of its FFI agreement.
In the case of existing accounts, the law envisages that all existing account relationships, which have been treated as US accounts, should con-
tinue to be treated as such for FATCA purposes. The “small accounts” (accounts with monthly average balance of less than USD 50,000) can
be treated as non-US accounts, unless the FFI elects otherwise.
Accounts with a balance or value that exceeds $ 50,000 but does not exceed $1,000,000 are subject only to review of electronically search-
able data for indicia of US status. No further search of records or contact with the account holder is required unless U.S. indicia are found
through the electronic search. Accounts with a balance that exceeds $1,000,000 are subject to review of electronic and non-electronic files for
U.S. indicia, including an inquiry of the actual knowledge of any relationship manager associated with the account.
Depending on the strength of the indicia, the FFI must request for documents and receive the same from the account holders. If the FFI does
not receive the requested documentation within specified time, the customer will be considered a recalcitrant customer and subject to 30%
withholding tax.
For individual accounts opened after the effective date of an FFI’s agreement, the FFI will be required to review the information provided at the
opening of the account, including identification and any documentation collected under AML/KYC rules. If U.S. indicia are identified as part of
that review, the FFI must obtain additional documentation or treat the account as held by a recalcitrant account holder.
Pre-existing entity accounts with account balances of $250,000 or less are exempt from review until the account balance exceeds
$1,000,000. For remaining pre-existing entity accounts, FFIs can generally rely on AML/KYC records and other existing account information
to determine whether the entity is an FFI, is a U.S. person, is excepted from the requirement to document its substantial U.S. owners (for
example, because it is engaged in a non-financial trade or business), or is a passive investment entity (referred to in the regulations as a “passive
NFFE”).
In the case of pre-existing accounts of passive investment entities with account balances that do not exceed $1,000,000, FFI's may generally
rely on information collected for AML/KYC due diligence purposes to identify substantial U.S. owners.
In the case of pre-existing entity accounts of passive investment entities with account balances that exceed $1,000,000, FFI's must obtain
information regarding all substantial U.S. owners or a certification that the entity does not have substantial U.S. owners.
The following new entity accounts are exempt from documentation of substantial U.S. owners:
l Accounts of another FFI (other than an owner-documented FFI for which the participating FFI has agreed to perform reporting);
and
l Accounts of an entity engaged in an active nonfinancial trade or business or otherwise excepted from documentation requirements.
With respect to the remaining entities (essentially, passive investment entities), FFIs will be required to determine whether the entity has any
substantial U.S. owners upon opening a new account, generally by obtaining a certification from the account holder.
The accounts identified as US accounts must be reported as a US account to the IRS by the 1st quarter 2015. The FFIs are required to report
information with regard to accounts of Specified US persons and US owned foreign entities.
As per the terms of the agreement, the following information will have to be reported to IRS:
l Name, address and TIN of each account holder in case the account belongs to a US tax payer;
l In case of accounts owned by entities, names, addresses and TINs of each substantial US owner of such entity
l Account balances, incomes, credits and gross proceeds
l Account number
The reporting of income is due only from 2016 and the reporting of gross proceeds will begin in 2017.
Fatca T24 components
The following applications are used by the FATCA module.
FATCA.PARAMETER
The FATCA. PARAMETER is used to record the details of the institution’s agreement with the IRS, the effective date of the FATCA provisions,
status (opt-in/opt-out) and certain default conditions.
The EFFECTIVE.DATE will be defaulted with a value of 01st Jan 2014 for agreements entered up to 31st Dec 2013. For agreements entered
after 31st Dec 2013 this field will be updated with the AGREEMENT.DATE.
The field INDICIA.STATUS.RTN should contain the id to the routine that will calculate the Indicia Status. The API FATCA.GET.INDICIA is
supplied, but a client may use their own routine. If no routine is specified the indicia strength will not be calculated.
The POTENTIAL.US.CALC.RTN should contain the id to the routine that will determine if the customer is defined with a potential us status.
The API FATCA.GET.POTENTIAL is supplied, but a client may use their own routine. If no routine is specified here then the Potential
US status will not be calculated
Some of the key details recorded here are for determining whether the FATCA Status (or Account classification) has to be updated by the sys-
tem automatically based on the rules defined in FATCA.STATUS.CONDITION (AUTO UPDATE STATUS set to ‘YES) and the cut-off date for
furnishing the documents by new (NEW.CLIENT.DOC.DAYS) as well as existing (EXIST.FFI.DOC.DAYS) clients.
Besides, the default status records for some of the standard classifications (US accounts, non-US accounts, non-participating FFIs, recalcitrant
accounts and dormant accounts), the identifier for dormant accounts and defaulting logic for the various address types in FATCA CUSTOMER
SUPPLEMENTARY INFO, are also defined here.
If the field AUTO.STATUS is set to Yes then the system can automatically default the FATCA.STATUS field in the
FATCA.CUSTOMER.SUPPLEMENTARY.INFO record depending on the rules specified.
For new clients it is possible to set the document defaults from the date of opening or the request date using the field
NEW.CLIENT.DAYS.FROM. The actual number of days is set in the field NEW.CLIENT.DOC.DAYS. In the example above the document cut
off has been specified for 90 days from the opening date.
The number of days by when the existing clients (FFIs) have to furnish the documents required under FATCA is specified in the field
EXIST.FFI.DOC.DAYS. The cut-off will be based on Effective date of FATCA Agreement plus the number of days specified in this field. As per
the requirement, this is currently one year.
For any documents that have expired if the AUTO.STATUS.UPDATE is set to Yes the system will automatically set the account classification
as recalcitrant, an additional grace period can be added using the EXPIRY.GRACE.DAYS, thus extending the timeframe client have to submit
new documentation.
If the address details in FATCA CUSTOMER SUPPLEMENTARY INFO are to be defaulted from existing DE ADDRESS records, the defaulting
conditions can be specified in the fields ADDR.TYPE and ADDR.RECORD. The ADDR.TYPE is the address type related to the DE.ADDRESS
record in ADDR.RECORD field. The example above shows that PERMANENT addresses will be default from PRINT.1 in the DE.ADDRESS
record.
D e fa ulting D or m a nt infor m a tion

It is possible to set up default dormant information using the fields DORM.IDENT.APP to DORM.IDENT.VALUE.
In the example above any customer with the field POSTING.RESTRICT set to "3" it will be classified as "Dormant".
In the example below the dormant details are being read from the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record
Any FATCA.CUSTOMER.SUPPLEMENTARY.INFO record with the field DORMANT.NO.CONTRACT set to Yes will be classified as
DORMANT.
Defaulting Fatca Status
FATCA.STATUSES are user defined in the FATCA.TAX.STATUS application, it is possible to set up default rule, these default rules are entered
in the FATCA.PARAMETER record in the following fields;
l DEFLT.RECALCITRANT
l DEFLT.ENTITY.RECAL
l DEFLT.DORMANT
l DEFLT.INACTIVE
l DEFLT.US.STATUS
l DEFLT.NONUS.STATUS
FATCA.TAX.STATUS
The FATCA.TAX.STATUS table is used to record the various account classifications or FATCA Statuses. A status has to be created here first
before it can be input in the field FATCA.STATUS of the FATCA.SUPPLEMENTARY.INFO.
A number of standard status records including, US.ACCOUNT, NON.US.ACCOUNT, RECALCITRANT, DORMANT, PARTICIPATING,
NON.PARTICIPATING and REGD. DEEMED.COMPLIANT, have been pre-defined in FATCA.TAX.STATUS. New status records can be added
as and when required
FATCA.STATUS.CONDITION
The FATCA.STATUS.CONDITION table is used to capture the conditions for the automatic update of the FATCA.STATUS field in the
FATCA.CUSTOMER.SUPPLEMENTARY.INFO record.
The fields DECISTION.FIELD to OPERAND form a multi value set which are used can be used to set conditions around the different doc-
umentation that is required for each classification.
The remaining fields are used for banks to set additional validation as required. For example if the field EXISTING.NEW is set to
l Existing -The conditions apply to those accounts opened before the FATCA effective date
l New - The condition applies to those opened either on or after the FATCA effective date
l Both - The condition applies to both new and existing clients
The following example is for the FATCA.STATUS US.ACCOUNT, if the details entered on the FATCA.CUSTOMER.SUPPLEMENTARY.INFO
record meet these requirement the record will be classified as an US.account.
FATCA.FORM.TYPE
The FATCA.FORM.TYPE is used to record the allowed document types.
The ID represents the document type that is being submitted. For example W9, W8BEN, FGN.PASSPORT, ANNUAL.OWNER. These IDS will
be part of the drop down list in the field FORM.TYPE in the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record.
The field US.DOCUMENT is used to specify whether this document establishes the US Status. This is set as Yes for documents like W9 as
shown above
The NON.US.DOCUMENT field is used to specify whether this document establishes the foreign status. For documents like W8BEN,
FGN.PASSPORT this will be set to Yes as shown below.
To specify whether the documents are allowed for entities the field ENTITY.ONLY should be set to Yes as shown below for the W8BEN-E doc-
ument.
FATCA.CUSTOMER.SUPPLEMENTARY.INFO
The FATCA.CUSTOMER.SUPPLEMENTARY.INFO record holds all the additional details required for classifying a client as US or non-US
under FATCA. Most of the details recorded here pertain to the indicia specifications (whether the client has a US Place of birth, whether he has
any US address, whether there is a POA or standing instruction to US, etc.). Besides, details regarding the client’s citizenship, green card,
social security number and Tax Identification number (TIN) are also recorded here. These details are recorded to determine whether any US
indicia is present and if yes, for flagging the accounts as Potential US account. Detailed due diligence can then be carried out to determine the
final classification of the account for FATCA purposes.
In the case of entity accounts, additional information regarding entity self classification and details of beneficial and substantial owners will
also have to be recorded. In the case of entity accounts, self-classification (in addition to documentation) will be used in determining the
FATCA status (account classification).
Documentation
Documentation is a key factor in determining the account classification as the final FATCA Status of the account is based on the doc-
umentation and not on the indicia.
FATCA.FORM.TYPE will be used to record the valid documents that will be accepted by the institution for ensuring FATCA compliance. Using
the form type table, new document type records can be created. Only the documents defined here will be accepted in FATCA CUSTOMER
SUPPLEMENTARY INFO for recording the documents received from individual clients and entities.
The receipt of any document (s) from the client can be recorded in FATCA CUSTOMER SUPPLEMENTARY INFO once a record is created for
the document type in FATCA.FORM.TYPE.
The details of document request date, document ID (EIN, Passport number), cut-off date for receiving the documents, receipt date and expiry
date are all recorded. If the documents are not received by the cut-off date or not renewed on expiry (with grace days, if applicable), the FATCA
STATUS will be automatically marked as recalcitrant provided AUTO STATUS UPDATE has been configured.
The DOCUMENT OWNER field is used to denote whether the documents have been received from the primary customer or the joint or bene-
ficial owner. The FATCA STATUS is not only based on the documents received from the primary customer but also on the status of joint or
beneficial owners. Even if one joint or beneficial owner is identified as a US person, the entire account will be classified as US Account. The doc-
uments received from the joint or beneficial owners are identified by means of the Unique ID of the joint or beneficial owner specified in
DOCUMENT OWNER field.
As mentioned above, the status of joint or beneficial owners has a bearing on the final account classification. It is, therefore, imperative that the
basic details of joint, beneficial and substantial owners are available.
Foreign Account Tax Compliance Act - Release R13.00 -Page 20 of 69 - (c) Temenos Systems 2013
If a CUSTOMER record exists for the owner, the ID of the CUSTOMER record can be entered in the CUSTOMER ID field.
The fields above are for recording the details of joint owners (in the case of individual clients). Similarly, the beneficial and substantial owner
details can also be recorded (with their respective role being specified in the ROLE.TYPE field).
If there are joint or beneficial owners, the status of joint or beneficial owners will be evaluated first before the status of the primary customer or
entity is evaluated. The joint or beneficial owners can have only the following statuses:
1. US Account – The beneficial or joint owner is US and has furnished W9 and Waiver
2. Non-US Account – The beneficial or joint owner is non-US and has furnished documents for the same (W8-BEN, etc.)
3. Recalcitrant – There is no response from the beneficial or joint owners by the cut-off date. As part of the batch process, the system
will automatically update the status of BO/JO as Recalcitrant.
Account classification (FATCA.STATUS) update

Once the customers have been assessed based on the documentation provided, they will be classified under different categories to determine
the impact of the FATCA regulations on the accounts. The FATCA.STATUS will be manually updated once the due diligence is completed.
For automatically updating the FATCA.STATUS based on documentation received, the field, AUTO STATUS UPDATE, in FATCA
PARAMETER has to be set as YES. It must be noted that the FATCA STATUS will only be based on the documentation and not the indicia. In
the case of legal entity accounts, the check will also be based on whether KYC has been done and the entity self classification.
The status update can happen either online or as part of the batch process:
1. Online – On input of the FATCA CUSTOMER SUPPLEMENTARY INFO with all document details
2. Batch – When
a. The documents that are required for FATCA Account classification expire and are not renewed by the expiry date (or end of
grace period where grace is applicable); and
b. The documents are not received by the cut-off date for both new and existing clients. The documents for which cut-off date is
specified will be tracked and if these documents are not received by then, the account classification (FATCA status) will be
automatically updated as part of the batch process.
The automatic update will be for both individual and entity accounts. It must be noted that the defaulted status can be manually changed with
the reason updated in CHANGE. REASON field.
The account classification logic is rule based. If there are any modifications (new documentation requirements, addition of new classifications,
etc.), these can be easily handled by changing the rules set. The conditions, based on which the account classification will be determined, is
given in FATCA.STATUS.CONDITION. The classification, as mentioned earlier, will be based only on the documentation (FORM.TYPE in
DECISION.FIELD). In the case of entity accounts, the entity self classification (as given in ENTITY.STATUS field) will also determine the final
account classification under FATCA.
In the following example for "PARTICIPATING" if both the FORM.TYPE's W8BEN-E and EIN have been received, and the self classification is
set to "Participating" then the classification will be "PARTICIPATING".
If the Joint owner/beneficial owner status has to be considered for determining the account classification (as in the case of Owner documented
FFIs that are US owned and Passive NFFEs with US substantial owners), CHECK.JO.BO.STATUS has to be set to YES.
In this case, the condition is set that the owner(s) status has to be checked and if the status is US.ACCOUNT, the account classification con-
dition will be considered met.
In the case of US accounts, it must be noted that even if one joint or beneficial owner is US, the account classification condition will be con-
sidered satisfied. If the classification is not updated for even one joint/beneficial owner or if the status of even one such owner is recalcitrant,
the FATCA STATUS will not be updated and exception log will be updated.
The joint or beneficial owner status will be checked only if CHECK.JO.BO.STATUS is set to YES.
The status updated can be manually changed with the reason, for the change, being recorded in CHANGE.REASON field.
If the rules change in FATCA.STATUS.CONDITION, the account classifications will be automatically updated.
Exception Handling
With rule based auto-status updates, there could be situations where the correct FATCA status could not be updated on account of a match
being not found. In such cases, the FATCA STATUS will not be updated but the EXCEPTION LOG field will be updated. It is assumed that
each account classification record will have unique set of conditions. The system will try to find the best fit and accordingly determine the
account classification. If there are conflicting conditions, the exception log will be updated. The users can then review the EXCEPTION LOG (a
field in FATCA CUSTOMER.SUPPLEMENTARY INFO) and correct the underlying data.
Indicia Strength and Potential Status
Indic ia Str e ngth

Based on the indicia details provided, the INDICIA STRENGTH will be automatically calculated by the system. Besides, the account will also
be flagged as POTENTIAL.US based on the indicia information.
The following fields are used to record the indicia strength and record the potential status of the customer based on the calculation logic.
These fields will be updated by the system .
l INDICIA.STRENGTH will be defaulted to a value of STRONG, MEDIUM or WEAK depending on the following
Strong 1 The fields
NATIONALITY,or
RESIDENCE or
DOMICILE or OTHER .NATIONALITY (from customer is US) or
CITIZENSHIP or
TAX.DOMICILE in the FATCA.SUPPLEMENTARY.INFO is US
OR
2 Client has a US Greencard
OR
3 TAX.RESIDENCE is US
4 In the case of joint accounts, if any joint holder is a US national or resident
Medium 1 BIRTH.PLACE is US
OR
2 Client has a US Permanent or Mailing Address
OR
3 Client has a standing instruction to or a standing instruction from US
Weak 1 HOLD.MAIL or INCARE or PO.BOX.ADDRESS is US or
OR
Has a POA to a person with a US Address
l POTENTIAL.US will default to Yes if
For Private/Retail 1 The field NATIONALITY, or
RESIDENCE, or
DOMICILE or
OTHER.NATIONALITY in the CUSTOMER record is US or
CITIZENSHIP or
TAX.DOMICILE in the FATCA.SUPPLEMENTARY.INFO. is US
OR
2 The client has a US Greencard
OR
3 TAX.RESIDENCE is US
OR
4 BIRTH.PLACE is US
OR
5 Client has a US Permanent or Mailing Address
OR
6 The client has a standing instruction to or instruction from the US
OR
7 TELEPHONE NUMBER
HOLD.MAIL or
IN CARE or
PO BOX ADDRESS is US
OR
8 Has a POA to a person with a US address
OR
9 For joint accounts, if any joint holder is a US national/resident or is US Domiciled
For In the case of entity accounts, the account will be considered a potential US account until the time there is no
FFI/NFFE/OTHER update regarding the substantial ownership/beneficial ownership details (The field BEN.SUBS.OWNER is not
equal to NO and no beneficial/substantial owner details have been provided).
If the BO/SO details have been provided and the Nationality or residence or domicile of such owner is US,
then the account will be considered a potential US account.
These are only indicative status fields and not the final account classification. The final account classification (FATCA.STATUS) along with the
status narrative is updated separately.
Pote ntia l s ta tus

Once the customers have been assessed on the documentation provided, they will be classified under different categories to determine the
impact of the FATCA regulations on the accounts. The fields FATCA.STATUS and STATUS .NARRATIVE are used to manually record this,
once validated/committed the STATUS,CHANGE.DATE field will be populated.
If there is a status change for the client then this is manually entered into the FATCA.STATUS and CHANGE.REASON fields
Other Updates
A number of live files are updated by the system in order to track the changes and automatically carry out updates based on these changes.
They are
l FATCA.ROLE.CUSTOMER
l FATCA.CONDITION.CHANGE
l FATCA.FCSI.AMENDMENTS
FATCA.ROLE.CUSTOMER
It is possible to specify an existing customer as Joint, beneficial or substantial owner in another FATCA CUSTOMER SUPPLEMENTARY
INFO record. The ID of the file, FATCA.ROLE.CUSTOMER, will be the customer number of the joint, beneficial or substantial owner (from the
CUSTOMER.ID field in FATCA.CUSTOMER.SUPPLEMENTARY.INFO). The record holds the ID of the
FATCA.CUSTOMER.SUPPLEMENTARY.INFO records where this customer has been included as other owner.
FATCA.CONDITION.CHANGE
The FATCA.CONDITION.CHANGE application is used to capture the date when there is any change in the FATCA.STATUS.CONDITION. The
information held in this file is used by the COB to rebuild the FATCA.STATUS (account classification) of all the clients affected by the change.
The following example shows that many new records have been added into the system on the 15JUN2012 and that a change has been made to
the record INTL.ORG on the 15th.
The id to the record will be the date that the FATCA.STATUS.CONDITION record(s) have changed. The field STATUS.ID is the id to a record
in the FATCA.STATUS.CONDITION table.
The field FUNCTION will be updated with one of the following
l ADD - For a new record in FATCA.STATUS.CONDITION

l DEL - For a record that has been reversed from FATCA.STATUS.CONDITION
l CHG - For a record that has been amended in FATCA.STATUS.CONDITION
For example the FATCA.STATUS.CONDITION record AFF.TRADE.NFFE is reversed
The record in FATCA.CONDITION.CHANGE has been amended for AFF.TRADE.NFFE it has changed from ADD to CHG,as shown below
FATCA.FCSI.AMENDMENTS
This live file is used to record the FATCA.CUSTOMER.SUPPLEMENTARY.INFO amendment dates for each FATCA customer. This concat file
will be updated during the authorisation of the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record. The information will be deleted if the
FATCA.CUSTOMER.SUPPLEMENTARY.INFO record is reversed.
API Overview
The following table contains details of API's that have been released with this module.
API Description
FATCA.GET.INDICIA This api has been released to get the INDICIA strength
FATCA.GET.POTENTIAL This API has been released to determine if the client is categorised as Potentially US or not
Fatca - Enquiries
The following enquiries are available as part of the FATCA module. These enquires can be used to interpret information on the
FATCA.CUSTOMER.SUPPLEMENTARY.INFO - Indicia details, documentation, joint/beneficial/subsyancial owner information and statuses.
1. FATCA client details - A master enquiry with indicia inforamtion and classification
2. Entity details – The details of entities with their self-classification and FATCA STATUS
3. Documentation received, expiring, nearing cut-off
4. Details of joint, beneficial and Substantial owners
5. Recalcitrant accounts
6. Dormant accounts
7. Status change history
8. Clients with status not updated
These can be found under the User Menu, FATCA Details under the sub menu's Customer Details, Document Details and Other Details. See
below;
Some of the enquiry results are shown below.
Enquiry Proven US
It is possible to drill down to the underlying FATCA.CUSTOMER.SUPPLEMENTARY.INFO records or edit them
Enquiry Proven Non US
Enquiry Documents Received
Customer Identification
Client identification requires the analysis of the existing customer base and at the on boarding of new clients. This includes the accounts of
both private customers and foreign entities to identify indicia of US status.
Fatca requires the financial institutions to classify all their accounts into one of the following three groups:
l US or Non-US accounts
l Individual (private) or entities
And in the case of entities as either;
l Financial or Non-Financial
A US account is an account held by one or more specified "US" persons or a "US" owned foreign entity. FFI's will be required to institute pro-
cedures to determine if the account belongs to a
l US Citizen
l Permanent Resident (Greencard holder)
l Person who satisfied the "Substantial Presence" test
l NFFE with a substantial US Owner
This chart details the process of the initial assessment for individual accounts. This applies to either single or jointly owned accounts. For
accounts which are jointly owned, if only one of the account owners is Proven US, the account will be considered a US account.
The following chart details the process of an initial assessment for an Entity account.
Within T24 this information is entered on the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record and API's are used to determine the indi-
cia and initial assessment.
Once the customers have been assessed on the initial documentation provided they are classified under different categories. This is a manual
classification and is entered into the field FATCA.STATUS in the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record.
Note: In addition to the documentation, the classification could also be based on whether KYC checks have been completed and the entity
self classification.
How to configure the FATCA.PARAMETER
Summary: What this How To will show you

This How To Guide will explain and show you how to configure the FATCA.PARAMETER for a financial institution who has entered into an
agreement with the IRS.
Pre-requisites
The FA module must be installed
Environment
The Screen shots, functionality and workflow are based on a Model Bank 201207 PB.
Overview:
The FATCA.PARAMETER record contains details of the agreement between the financial institution and the IRS.
Scenario:
Company GB0010001 has entered into an agreement with the IRS on 07MAR2012. The agreement date was 07MAR2012. The company has
an EIN of 01-9991119.
The company has decided to use the Temenos API's to calculate Indicia and status.
It is required that FATCA.STATUS field is automatically updated in the FATCA.CUSTOMER.SUPPLEMENTARY INFO record and the bank
wants to set up various defaults.
Set dormant information based on the POSTING.RESTRICT field in CUSTOMER .
Steps:
Step 1
Create a FATCA.PARAMETER record for company GB0010001. In the Admin Menu select Framework Parameter>Customer> FATCA Admin
Menu>FATCA Parameter.
Enter the following fields
l STATUS is OPT.IN
l AGREEMENT.DATE as 07MAR2012
l EIN is 01-9991119
l INDICIA.CALC.RTN is FATCA.GET.INDICIA
l POTENTIAL.CALC.RTN is FATCA.GET.POTENTIAL
The EFFECTIVE.DATE field will default to the 01JUL2013 as the agreement date is before 30 June 2013.
For the status to be automatically updated the field AUTO.UPDATE.STATUS should be set to Yes.
The following fields are used to specify how long client have to produce the relevant documentation.
Enter the fields DORM,IDENT.APP to DORM.IDENT.VALUE to automatically identify dormant accounts. In this example the fields should be
set as following
l DORM.IDENT.APP - CUSTOMER
l DORM.IDNT.FIELD - POSTING.RESTRICT
l DORM.IDENT.OPERAND - EQ
l DORM.IDENT.VALUE - 3
With the above settings the system will identify dormant customers with a POSTING.RESTRICT of 3.
In the above example various FATCA.TAX.STATUS records have been defined in the following default fields
l DEFAULT.RECALCITRANT
l DEFAULT.RECAL.ENTITY
l DEFAULT.DORMANT
l DEFLT.INACTIVE
l DEFLT.US.STATUS
l DEFLT.NON.US.STATUS
Step 2
Authorise the record.
How to configure a new FATCA TAX STATUS record

This How To Guide will explain and show you how to enter a new FATCA.TAX.STATUS record.
Pre-requisites
The FA module must be installed.
Environment
Overview:
Recognised FATCA.TAX.STATUS record have been released in T24. However, it is possible that additional recognised status records may be
required. It is possible to enter these new records in the FATCA.TAX.STATUS application
Scenario:
A new record is required for US-CITIZEN.
A new record is required - DECEASED
Steps:
Enter a new record in the FATCA.TAX.STATUS application. Select Tax Status
Enter the new FATCA.TAX.STATUS id and select Edit
Enter a description for this record.
And authorise the record.
How to configure FATCA.STATUS.CONDITION records

This How To Guide will show you how to configure the FATCA,STATUS.CONDITION records. Which will enable the automatic update of the
FATCA.STATUS.
Pre-requisites
Environment
Overview:
Recognised FATCA.STATUS.CONDITION record have been released in T24 Model Bank. However, it is possible that additional recognised
status records may be required. It is possible to enter these new records in the FATCA.status.condition application
Scenario:
Create the condition for the FATCA.STATUS US.ACCOUNT, to be classified as US.ACCOUNT it is required that both the W9 and WAIVER
forms are received.
Steps:
In the Admin Menu select Framework Parameter>Customer> FATCA Admin Menu>Fatca status condition
Enter the ID of the FATCA.TAX.STATUS record that the conditions will apply as the @ID to the FATCA.STATUS.CONDITION record
Select the edit button and enter the conditions into the record
Mutlti value the Descition field set of fields in multi value set 1 enter
l DESCISION FIELD.1 - FORM.TYPE

l DESCISION.1 - EQ
l DESICION VALUE.1 - W9
l DESCISION FIELD.2 - FORM.TYPE
l DESCISION.2 - EQ
l DESICION VALUE.2 - WAIVER
Enter a narrative for this.
Commit and authorise the record.
Once configured when a FATCA.CUSTOMER.SUPPLEMENTARY.INFO record is entered, if the details entered satisfy any of the conditions on
this table, and the field AUTO.UPDATE.STATUS is set to Yes in the FATCA.PARAMETER then the ACCOUNT CLASSIFICATION will be auto-
matically set.
Its is possible to set other requirements, for example the field EXISTING.NEW can be set so that this condition only applies to new clients,
existing clients or both.
Please refer to the Helptext for more information on these fields.
How to use FATCA.CUSTOMER.SUPPLEMENTARY.INFO

This How To Guide will explain and show you how to enter FATCA details for a customer, where the FATCA.PARAMETER is configured for
manual classification. The system will calculate Indicia and Provenus status.
Pre-requisites
Environment
Overview:
The bank is updating KYC details in regards to FATCA.
Scenario:
The bank is entering the following details for a private individual customer;
l CUSTOMER NUMBER 100101

l Place of birth is US
l Tax domicile is US
l Citizenship is US
l Tax residence is US
l There is a waiver in place dated 07 Mar 2012
l His address is permanent with a US address
Based on these details the client should be classified as PROVEN.US with a STRONG Indicia.
Steps:
Enter the information into a FATCA.CUSTOMER.SUPPLEMENTARY.INFO record.
The id to the record is CUSTOMER.NO.
From the User Menu, select the FATCA.Details Menu and FATCA Client Info.
Enter the customer number then select the edit button .
Enter the following fields in the FATCA Customer Details Tab;
l CLIENT.TYPE is Private
l BIRTH.PLACE is US
l TAX.DOMICILE is US
l CITIZENSHIP is US
l TAX.RESIDENCE is US
l Address Type is Permanent
l Address Country is US
In the Document Details Tab enter;
l FORM.TYPE is W9
l Enter info into the other fields as required
In the Indicia Details Tab, when the validate button is selected the system will return a value in the INDICIA.STRENGTH and a recom-
mendation. In this example the system returns;
l Indicia strength of Strong

l Proven US is Yes
As a result of this the FATCA.STATUS of US-ACCOUNT can be entered.
Due to the information that has been entered about this customer the system has returned the Indicia Strength of Strong and Proven US is
Yes, the customer record confirms that this customer has a us nationality and residence.
Fatca - Automatic update of the FATCA.STATUS in FCSI

This How To Guide will explain and show you how the FATCA.STATUS can be automatically updated in the FATCA.SUPPLEMENTARY.INFO
records.
Pre-requisites
The Fatca module must be installed and configured.
Environment
The Screen shots, functionality and workflow are based on a Model Bank R12.
Overview:
The FATCA.STATUS update can happen either online or as part of the batch process.
1. Online - On input of the FATCA.CUSTOMER.SUPPLEMENTARY.INFO with all document details

2. Batch - When
l The documents that are required for fatca account classification expire and are not renewed by the expiry date (or end of grace
period where this has been set) and
l The documents are not received by the cut-off date for both new and existing clients. The documents for which the cut-off
date is specified will be tracked, and if these are not received by then, the account classification (FATCA.STATUS) will be auto-
matically updated as part of the batch process.
The automatic update will be for both individual and entity accounts.
The FATCA.STATUS that is calculated by the system can be manually changed, and the reason for the change entered in the field
CHANGE.REASON.
The following table explains the logic for the automatic update of FATCA.STATUS for individual clients. Individual clients are those whose
CLIENT.TYPE is
l RETAIL
l PRIVATE
l INDIVIDUAL
l BLANK
Indicia Contact Documentation FATCA.STATUS Narrative
Yes Yes W9 and Waiver received US_ACCOUNT W9 and Waiver received

(note 1)
Yes No (Note 2) No DORMANT Dormant No Contact
Yes Yes No (Note 3) RECALCITRANT) No Response
Yes Yes W8BEN or other foreign NON_US_ACCOUNT Foreign documents

doc received (Note 4) received
No Yes W8BEN or other foreign NON_US_ACCOUNT Foreign documents

doc received (Note 4) received
No No (Note 2) No DORMANT Dormant No Contact
Indicia Contact Documentation FATCA.STATUS Narrative
No Yes No (Note 3) RECALCITRANT No Response
No Yes W9 and Waiver received US_ACCOUNT W9 and Waiver received

(Note 1)
Documentation expired RECALCITRANT Documents Expired

and renewed documents
not furnished by the expiry
date or within the grace
period allowed
Note 1 - If the W9 is received from even one party (joint or beneficial owner) then the account will be considered a US account. If there are
no joint /beneficial owners, then the waiver has to be obtained from the primary customer. If there are joint /beneficial owners the waivers
have to be obtained from each US owner and also the primary customer.
Note 2 - The accounts with which no contact could be established.
Note 3 - If the documents are not received by the cut off date, the status will be set as recalcitrant on the expiry of the cut-off period. For
new clients, this period is now 90 days and for other existing clients it is either one year or two years based on the type of client (FFI or
not). In the case of accounts with joint/beneficial owners , the documents will have to be received from all the owners by the cut-off date.
Even if one document is not received the account will be considered recalcitrant.
Note 4 - The documents must be received from all the joint and beneficial owners, even if one joint or beneficial owner is US, the account
will be considered an US_ACCOUNT.
All documents will be considered as Received only when the field FORM.DATE in the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record is
updated.
Rule based account classification

The account classification within T24 will be rule based. A unique set of rules must be created for the FATCA.TAX.STATUS. For example an
account maybe classified as US_ACCOUNT if the following conditions are met.
l DOCUMENT.TYPE is W9 and
l DOCUMENT.TYPE is Waiver and
l RECEIVED.DATE is not null or expired for both document types.
The following data has been captured for three clients
Client 1 111714 Client 2 111715 Client 3 111716
DOCUMENT.TYPE-1 W9 W9 W9
REQUESTED.DATE 01JUN2012 01JUN2012 01JUN2012
FORM.DATE-1 22JUN2012 22JUN2012 01JAN2013
FORM.TYPE-2 Waiver Waiver
REQUESTED.DATE 01JUN2012 01JUN2012
FORM.DATE-2 22JUN2012
Account Classification US_ACCOUNT (1) Blank (2) Blank(3)
1. In this case, both the documents have been received so the account is automatically classified US_ACCOUNT
2. In this case, only the W9 has been requested and received, as this does not met the requirements then no automatic classification can
be made
3. In this case, even though both documents have been requested only the W9 has been received so the automatic classification can not
be done
Scenario:
The automatic update of the FATCA.STATUS is required for US_ACCOUNTS.
Steps:
Step 1
In the FATCA.PARAMETER record set the field AUTO.STATUS.UPDATE as Yes
Step 2
In the application FATCA.STATUS.CONDITION enter the criteria for the FATCA.TAX.STATUS US_ACCOUNT
l ID is US_ACCOUNT
l DECISION.FIELD is FORM.TYPE
l DECISION is EQ
l DECISION.VALUE is W9
l LEVEL is 1
l OPERAND is AND
l DECISION.FIELD is FORM.TYPE
l DECISION is EQ
l DECISION.VALUE is WAIVER
l LEVEL is 2
Enter the FATCA.CUSTOMER.SUPPLEMENTARY.INFO records for the clients.
Customer 111714
For customer 111714 the correct documents have been both requested and received. As both of the required documents have been received and
the details entered on the Document details Tab, once the record is committed the automatic classification has been correctly updated as
US Account.
Customer 111715
For Customer 111715, the document details do not met the requirements the Account classification has been updated as "No Match Found".
This account will not be automatically classified until the Waiver document has been received.
Customer 111716
For customer 111716 even though the W9 form has been received and the waiver has been requested it does not met the requirements for clas-
sification. As such the account classification has been updated as no match found until the waiver details have been entered. Then this can be
re-classified.
Fatca - Customer Categorisation - Proven Non US

This How To Guide will show an example customer being classified as Proven Non US and the subsequent categorisation for FATCA.
Pre-requisites
The Fatca Module must be installed and configured.
Environment
Overview:
A customer is being assessed using due diligence for FATCA.
Scenario:
The private customer Liliane Dassault has the following details;
l Tax Domicile is France

l Tax Residence is France
l Citizenship is France
l Permanent Address country of US and a Us telephone number
l Documentation supplied French passport which expires 6 March 2015
Steps:
From the User Menu, select the FATCA Details Menu
Then select Update Fatca Details
Enter the customer number the select the edit button .
When the record is opened the system will open a version, enter the client details in the FATCA Customer Details tab.
Based on the customer details entered so far if the validate button is selected the system will updte the indicia details tab.
l An Indicia Strength of Strong
l Is Proven Non US
The Indicia Strength has been returned as strong because the underlying customer record has a residence of US.
Enter the document details into the Document details tab
Once the customer has been assessed on the documentation provided, it is then further classified to determine the impact of the Fatca reg-
ulations on the account. In this example the customer has been determined as Proven Non US. This will mean that the customer will be cat-
egorized as NON-US.ACCOUNT.
The category is entered into the field FATCA.STATUS.
Commit and authorise the record.
Once validated the Indicia details are cleared as the account has been classified .
Fatca - Customer Categorisation - Entity

This How To Guide will show an example categorisation for an entity.
Pre-requisites
The FATCA module must be installed and configured.
Environment
Overview:
A Non Financial Foreign Entity is being assessed using due diligence for FATCA.
Scenario:
The customer Star Bakery has provided the following information.
l Incorporation non us, ,

l Registered Country is GB,
l Self classification is NON US Account
l A W8Ben-E form has been supplied.
Steps:
From the User Menu, select the FATCA Details Menu , then select Update Fatca Details -Entity.
Enter the customer number the select the edit button .
In the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record, enter the above details on the Customer details tab.
Enter the document details the document details tab
l Form.Type is W8Ben
l Received date is today
Once validated or committed the system should return a classification as long as the entered details match the criteria. In this example this it
has been classified as Non US Account as expected
Fatca - Customer Categorisation - Joint example

This How To Guide will show an example categorisation with joint customer details.
Pre-requisites
The FATCA module must be installed.
Environment
Overview:
A Customer is being assessed using due diligence for FATCA.
Scenario:
Customer Fiona Jones is being assessed for FATCA. The following details have been provided as GB;
l Birth place Non US

l Tax domicile
l Citizenship
l Tax Residence
l Permanent Address
l Telephone number NON US
l A W8BEN Form has been produced
There is a joint holder customer 111334 who has a residence and nationality of US and classified as a US account.
Steps:
From the User Menu, select the FATCA.Details Menu and Update FATCA Details.
Enter the customer number and click the edit button .
Enter the clients details into the Fatca Customer Details for customer 111661
Enter the document details for the customer.
l Document type of W8BEN

l Received date is today
When the document details are added for customer 111661 the system will classify this as a Non us account.
When joint account holders are added to the record, these may have an impact on how a classification is made. A joint owner is added to the
FATCA.SUPPLEMENTARY.INFO record for Customer 111661. This new customer is classified as US.ACCOUNT using the fields
JO.CLASSIFICATION.
Note If there are joint or beneficial owners, in order to get the classification the field JO.CLASSIFICATION should be completed.
When updated the classification is updated. As the joint owner is a US ACCOUNT then the classification of customer 111661 is now also a us
account. The specific classification is US ACCOUNT JOINT, as shown below.
Fatca - Customer Categorisation - Deemed Compliant Retirement Plan

This How To Guide will show you an example of a Customer which is automatically classified as classified as a "Deemed compliant Retirement
Plan".
Pre-requisites
Fatca module must be installed and configured.
Environment
Scenario:
The customer Eagle Retirement Plan is a US based retirement fund company. They have submitted documentation for FATCA classification
W9. They are based in the US.
Steps:
The following conditions have been released in Model bank.
The FATCA.TAX.STATUS record CERT.DEEM.COMP.RP has been entered in the system.
For a customer to be classified they have to meet the following requirements
Steps
From the Fatca Details menu select "Update FATCA Details -Entity"
Enter the customer number and edit the record
Enter the client details in the Entity details tab, the field CLIENT.SELF.CLASSIFICATION should be entered otherwise no customer clas-
sification will be made. Based on the information above the following fields should be completed
l Client type - Retirement Fund

l Incorporated in US - Yes
l Registered Country - US
l Client Self Classification - CERT.DEEM.COMP.RP
In this example this field should be set to
If the record is validated at this stage or committed the system will update the Indicia details as shown below based on the information entered
in the Entity details tab. In this example it has been calculated as an
l Indicia strength - Strong

l Potential US of - Yes
Enter the document details in the Document details tab. nThe following fields are required for classification
Document.Type - W9
Received.Date - todays date
Once the record is either validated or committed the classification details will be calculated and updated if they meet the required rules for this
classification. As shown below the details entered have met the requirements for CERT.DEEM.COMP.RP.
Authorise the record.
Once the classification has been completed the Indicia fields are cleared.
APPENDIX 1 - Fatca Key Dates
Please find below the Fatca Key Dates.
Year Date Description
2010 March 18, Hire Act passed including FATCA provisions -

2010
New rules became applicable to foreign securities lending transactions where the purpose is tax reduc-
tion or elimination.
August 27, IRS issues Notice 2010-60 -Provides initial guidance describing the requirements to become a par-
2010 ticipating Foreign Financial Institution (participating FFI) including documentation due diligence pro-
cedures and reporting requirements (official publication in Internal Revenue Bulletin, September 13,
2010)
2011 April 8, 2011 IRS issues Notice 2011-34- Provides additional and amended guidance on documentation of pre-exist-
ing accounts, passthru payments and reporting requirements (official publication in Internal Revenue
Bulletin, May 9, 2011).
July 25, 2011 IRS issues revised Notice 2011-53 (originally released July 14, 2011) - Transitional relief for pre-exist-
ing account due diligence and FATCA withholding and reporting.
2012 February 8, IRS issues Proposed FATCA regulations

2012
Summer 2012 Treasury and the IRS anticipate issuing draft versions of the FFI agreement and reporting forms.
December 2012 Treasury and the IRS anticipate issuing final regulations, final FFI Agreement and FATCA reporting
forms.
December 31, Qualified Intermediary and Other Withholding Agreements expiring on this date will be automatically
2012 extended until December 31, 2013.
2013 January 1, Effective date of FATCA legislation.

2013
Grand fathered obligations - New end date for obligations to be exempt from FATCA withholding (pre-
viously March 18, 2012.)
Expected - FFI Agreements ready to be executed in early 2013
2014 January 1, Effective date of FFI Agreements if entered into by December 31, 2013.
2014
January 1, Requirement to implement new account onboarding procedures for U.S. Withholding Agents, Par-
2014 ticipating FFIs, and Registered Deemed-Compliant FFIs.
January 1, FATCA withholding on Fixed, Determinable, Annual, Periodical (FDAP) income payments to non-par-
2014 ticipating FFIs and recalcitrant payees begins.
June 30, 2014 U.S. Withholding Agents, Participating FFIs, and Registered Deemed-Compliant FFIs must document
preexisting entity accounts identified as Prima Facie FFIs. If the FFI signed an agreement after January
1, 2014, the deadline is six months from the effective date of the FFI agreement.
December 31, Participating FFIs must document preexisting high value individual accounts by December 31, 2014. If
2014 the FFI signed an agreement after January 1, 2014, the deadline is one year from the effective date of
the FFI agreement.
Year Date Description
2015 March 15, 2015 Reporting on withholdable income payments begins (with respect to the 2014 calendar year.)
March 31, 2015 FFIs begin U.S. Account information and balance reporting (with respect to the 2013 and 2014 cal-
endar years.)
December 31, U.S. Withholding Agents, Participating FFIs, and Registered Deemed-Compliant FFIs must document
2015 preexisting entity accounts not identified as Prima Facie FFIs. If the FFI signed an agreement after Janu-
ary 1, 2014, the deadline is two years from the effective date of the FFI agreement.
December 31, Participating FFIs must document all remaining preexisting non-high value individual accounts by
2015 December 31, 2015. If the FFI signed an agreement after January 1, 2014, the deadline is two years
from the effective date of the FFI agreement.
2016 January 1, Deadline for limited FFIs (due to local regulations prohibiting FATCA compliance) to become par-
2016 ticipating FFIs and avoid other participating FFIs within the expanded affiliated group from losing their
participating FFI status.
March 31, 2016 Reporting on U.S. Account income by participating FFIs begins (with respect to the 2015 calendar
year.)
2017 January 1, 2017 FATCA withholding on gross proceeds payments to non-participating FFIs and recalcitrant payees
begins.
January 1, 2017 Withholding on foreign pass-thru payments begins not before January 1, 2017. (previously January 1,
2015)
March 15, 2017 Reporting on U.S. Account gross proceeds by participating FFIs begins (with respect to the 2016 cal-
endar year.)
2018 March 15, 2018 Reporting on gross proceeds begins (with respect to the 2017 calendar year.)

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Foreign Account Tax Compliance Act

FATCA Foreign Account Tax Compliance Act

FFI Foreign Financial Institution

USFI US Foreign Institution

NFFE Non Financial Foreign Entity

PFFE Participating Financial Foreign Entity

Generally speaking, an FFI Agreement requires;

l A determination of which accounts are “United States accounts” (a defined term),

Wha t is a U S Subs ta ntia l owne r ?

l Account holder is a US citizen or resident

The following applications are used by the FATCA module.

D e fa ulting D or m a nt infor m a tion

Defaulting Fatca Status

Account classification (FATCA.STATUS) update

Indicia Strength and Potential Status

Indic ia Str e ngth

DOMICILE or OTHER .NATIONALITY (from customer is US) or

TAX.DOMICILE in the FATCA.SUPPLEMENTARY.INFO is US

2 Client has a US Greencard

4 In the case of joint accounts, if any joint holder is a US national or resident

2 Client has a US Permanent or Mailing Address

3 Client has a standing instruction to or a standing instruction from US

Weak 1 HOLD.MAIL or INCARE or PO.BOX.ADDRESS is US or

Has a POA to a person with a US Address

l POTENTIAL.US will default to Yes if

OTHER.NATIONALITY in the CUSTOMER record is US or

TAX.DOMICILE in the FATCA.SUPPLEMENTARY.INFO. is US

2 The client has a US Greencard

5 Client has a US Permanent or Mailing Address

6 The client has a standing instruction to or instruction from the US

8 Has a POA to a person with a US address

9 For joint accounts, if any joint holder is a US national/resident or is US Domiciled

Pote ntia l s ta tus

The field FUNCTION will be updated with one of the following

l ADD - For a new record in FATCA.STATUS.CONDITION

For example the FATCA.STATUS.CONDITION record AFF.TRADE.NFFE is reversed

FATCA.GET.INDICIA This api has been released to get the INDICIA strength

Some of the enquiry results are shown below.

Enquiry Proven Non US

Enquiry Documents Received

And in the case of entities as either;

Summary: What this How To will show you

Set dormant information based on the POSTING.RESTRICT field in CUSTOMER .

Enter the following fields

Authorise the record.

Summary: What this How To will show you

A new record is required - DECEASED

Enter the new FATCA.TAX.STATUS id and select Edit

Enter a description for this record.

Summary: What this How To will show you

l DESCISION FIELD.1 - FORM.TYPE

Enter a narrative for this.

Commit and authorise the record.

Please refer to the Helptext for more information on these fields.

Summary: What this How To will show you

l CUSTOMER NUMBER 100101

The id to the record is CUSTOMER.NO.

Enter the following fields in the FATCA Customer Details Tab;

l Indicia strength of Strong