You are on page 1of 123

Foreign Account Tax Compliance Act - User Guide

Release R15.000
June 2015

©2015 Temenos Headquarters SA - all rights reserved.

Warning: This document is protected by copyright law and international treaties. Unauthorised reproduction of this document, or any portion of it, may
result in severe and criminal penalties, and will be prosecuted to the maximum extent possible under law.
Table of Contents
Introduction 5
Purpose of this Guide 5
Intended Audience 5
Foreign Account Tax Compliance Act - Overview 6
Prerequisites 7
Abbreviations 8
Financial Institutions 9
Recalcitrant Accounts 9
US Accounts 10
Major Areas of Impact 11
Indicia of US Status 12
Fatca T24 Components 14
FATCA.PARAMETER 15
FATCA.TAX.STATUS 18
FATCA.STATUS.CONDITION 20
FATCA.FORM.TYPE 21
FATCA.CUSTOMER.SUPPLEMENTARY.INFO 22
Documentation 25
Account Classification (FATCA.STATUS) Update 29
Exception Handling 31
Indicia Strength and Potential Status 32
Indicia Strength 32
Potential Status 34
FATCA Balance Aggregation 35
Other Updates 39
FATCA and Customer Relationship 40
Setup 41
FATCA.ROLE.CUSTOMER 43
FATCA.CONDITION.CHANGE 44
FATCA.FCSI.AMENDMENTS 46
API Overview 47
Customer Identification 48
How to Configure the FATCA.PARAMETER 51
Summary: What this How To Shows You 51
Prerequisites 51
Environment 51
Overview 51
Scenario 51
Steps 51
How to Configure a New FATCA TAX STATUS Record 55
Summary: What this How To Shows You 55
Prerequisites 55
Environment 55
Overview 55
Scenario 55
Steps 56
How to Configure FATCA.STATUS.CONDITION Records 57
Summary: What this How To Shows You 57
Prerequisites 57

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 2 of 123
Environment 57
Overview 57
Scenario 57
Steps 58
How to Use FATCA.CUSTOMER.SUPPLEMENTARY.INFO 60
Summary: What this How To Shows You 60
Prerequisites 60
Environment 60
Overview 60
Scenario 60
Steps 60
Fatca - Automatic Update of the FATCA.STATUS in FCSI 65
Summary: What this How To Shows You 65
Prerequisites 65
Environment 65
Overview 66
Scenario 67
Steps 68
Fatca - Customer Categorisation - Proven Non US 74
Summary: What this How To Shows You 74
Prerequisites 74
Environment 74
Overview 74
Scenario 74
Steps 74
Fatca - Customer Categorisation - Entity 78
Summary: What this How To Guide Shows 78
Prerequisites 78
Environment 78
Overview 78
Scenario 78
Steps 78
Fatca - Customer Categorisation - Joint Example 81
Summary: What this How To Shows You 81
Prerequisites 81
Environment 81
Overview 81
Scenario 81
Steps 82
Fatca - Customer Categorisation - Deemed Compliant Retirement Plan 85
Summary: What this How To Shows You 85
Prerequisites 85
Environment 85
Scenario 85
Steps 85
FATCA Reporting 89
Overview 89
Reporting 90
Reporting of Recalcitrant Account Holders 91
Reporting Parameter 92
FATCA TAX BASE 97
POOL REPORTING 104
Form 8966 106
Who Must File 106
How and When to File 107

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 3 of 123
PFFI Reporting 107
Information to be Reported 108
Currency Translation 108
Transitional Reporting for 2014 and 2015 108
Form 8966 – Paper Filing 109
Electronic Filing – Schema Instructions 111
Form 8966 XML File Creation 118
APPENDIX 1 - Fatca Key Dates 122

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 4 of 123
Introduction

Purpose of this Guide


The Banking Framework User Guides provide a profound insight into the developments and changes to the Core Financial Products and Core
Financial Services of T24.

Intended Audience
This Banking Framework User Guides are intended for T24 Customers and Internal Stakeholders to stay informed of the latest developments
and changes on the Licensed Core Financial Products and Core Financial Services of T24, which are constantly revised and upgraded to leverage
new technologies and new technical architectures.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 5 of 123
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 has 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 are 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 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 in turn reports the information to US (this is mostly on a reciprocal basis). Although, IGA is applicable only to five coun-
tries as of now, it is expected that many countries (both EU and non-EU) become FATCA partners under IGA.

Withholding taxes (30%) 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 does not have to withhold
the payment but the PFFI will have to apply the withholding to its investors – both US and non US persons – if they are not in compliance
with requirements of FATCA.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 6 of 123
Prerequisites

The following contains a list of prerequisites for this Module.

Component

FA module has been installed, for installing a new module. Refer to the "Installing a new Product User Guide".

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 7 of 123
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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 8 of 123
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 has a direct impact on FFIs that have US proprietary investments, US account holders or US financial
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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 9 of 123
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.

What is a US Substantial Owner?


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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 10 of 123
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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 11 of 123
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 are subjected to closer scrutiny to determine whether it belongs to a US person.

A participating FFI has 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 the 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 is required to review the information provided at the open-
ing 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 non-financial trade or business or otherwise excepted from documentation requirements.

With respect to the remaining entities (essentially, passive investment entities), FFIs are required to determine whether the entity has any sub-
stantial 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:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 12 of 123
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 was due only from 2016 and the reporting of gross proceeds began in 2017.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 13 of 123
Fatca T24 Components

The following applications are used by the FATCA module:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 14 of 123
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 is 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 is updated with the AGREEMENT.DATE.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 15 of 123
The field INDICIA.STATUS.RTN should contain the ID to the routine that calculates the Indicia Status. The API FATCA.GET.INDICIA is sup-
plied, but a client may use their own routine. If no routine is specified, the indicia strength is not calculated.

The POTENTIAL.US.CALC.RTN should contain the ID to the routine that determines 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
is not 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 is based on Effective date of FATCA Agreement along with 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 automatically sets 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 are default from PRINT.1 in the DE.ADDRESS record.

Defaulting Dormant Information


It is possible to set up default dormant information using the fields DORM.IDENT.APP to DORM.IDENT.VALUE.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 16 of 123
In the example above any customer with the field POSTING.RESTRICT set to "3" is 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 is classified as DORMANT.

Defaulting Fatca Status


FATCA.STATUSES are user defined in the FATCA.TAX.STATUS application. It is possible to set up a 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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 17 of 123
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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 18 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 19 of 123
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 meets these requirements, the record will be classified as a US.account.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 20 of 123
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 and so on.
These IDS are a 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 is 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
document.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 21 of 123
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 and so on). 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 22 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 23 of 123
In the case of entity accounts, additional information regarding entity self classification and details of beneficial and substantial owners also
have to be recorded. In the case of entity accounts, self-classification (in addition to documentation) is used in determining the FATCA status
(account classification).

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 24 of 123
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 is used to record the valid documents that are 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 are 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 is automatically marked as recalcitrant, provided AUTO STATUS UPDATE has been configured.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 25 of 123
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 - User Guide - Release R15.000 - Page 26 of 123
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 is evaluated first before the status of the primary customer or
entity is evaluated. The joint or beneficial owners can have only the following statuses:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 27 of 123
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
automatically updates the status of BO/JO as Recalcitrant.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 28 of 123
Account Classification (FATCA.STATUS) Update

After the customers have been assessed based on the documentation provided, they are classified under different categories to determine the
impact of the FATCA regulations on the accounts. The FATCA.STATUS is 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 is only based on the documentation and not the indicia. In the
case of legal entity accounts, the check is also 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:

l Online – On input of the FATCA CUSTOMER SUPPLEMENTARY INFO with all document details
l Batch – When
o 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
o The documents are not received by the cut-off date for both new and existing clients. The documents for which, cut-off date
specified is tracked and if these documents are not received by then, the account classification (FATCA status) is auto-
matically updated as part of the batch process.

The automatic update is 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
and so on ), these can be easily handled by changing the rules set. The conditions, based on which the account classification is determined, is
given in FATCA.STATUS.CONDITION. The classification, as mentioned earlier, is 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) also determines 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".

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 29 of 123
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), the CHECK.JO.BO.STATUS should 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 is 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 is considered
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 is not updated and exception log is updated.

The joint or beneficial owner status is checked only if CHECK.JO.BO.STATUS is set to YES.

The status updated is 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 are automatically updated.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 30 of 123
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 is not updated but the EXCEPTION LOG field is updated. It is assumed that each account
classification record has a unique set of conditions. The system tries to find the best fit and accordingly determines the account classification.
If there are conflicting conditions, the exception log is updated. The users can then review the EXCEPTION LOG (a field in FATCA
CUSTOMER.SUPPLEMENTARY INFO) and correct the underlying data.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 31 of 123
Indicia Strength and Potential Status

Indicia Strength
Based on the indicia details provided, the INDICIA STRENGTH is automatically calculated by the system. Besides, the account is also 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 are updated by the system.

l INDICIA.STRENGTH is defaulted to a value of STRONG, MEDIUM or WEAK depending on the following:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 32 of 123
Strong 1 The following fields should indicate US:

l NATIONALITY or
l RESIDENCE or
l DOMICILE or OTHER .NATIONALITY (customer is from US) or
l CITIZENSHIP or
l TAX.DOMICILE in the FATCA.SUPPLEMENTARY.INFO

OR

2 The client has a US Green Card

OR

3 TAX.RESIDENCE is US

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

5 HOLD.MAIL or INCARE.ADDR or PERM.ADDR or MAIL.ADDR or PO.BOX.ADDRESS is US

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.MAIL or PO.BOX.ADDRESS is a non-US address

OR

Has a POA with a non-US Address

l POTENTIAL.US defaults to Yes if:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 33 of 123
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 is 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 is 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.

Potential Status
Once the customers have been assessed on the documentation provided, they are 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 val-
idated/committed, the STATUS,CHANGE.DATE field is populated.

If there is a status change for the client, then this is manually entered into the FATCA.STATUS and CHANGE.REASON fields.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 34 of 123
FATCA Balance Aggregation

A Financial Institution must consider aggregation of accounts of both individuals and entities in certain circumstances.

Aggregation is only required to the extent that a Financial Institution’s computerized system can link the account by reference to a data element
such as a customer or taxpayer identification number or by a name and address.

It is not necessary for the computer system to sum/total the balances of the accounts for the aggregation rule to apply. So where accounts can
be linked by a data element but the system does not provide an aggregated balance of the accounts, aggregation is still required.

The Financial Accounts (pre-existing, that is; existing prior to July 1st 2014) are classified in to the following three categories:

l Identify individual accounts with balance or value less than $ 50,000


l Identify entity accounts with balance or value less than $ 250,000
l Identify high value accounts with balance or value > or equal to $ 1 million

The accounts with balance less than $50000, for individuals, and less than $250000, for entities, can be treated as non-US accounts and not
subject to any due diligence whereas the high value accounts are subjected to enhanced due diligence. The balance check is run at close of busi-
ness on 30th June 2014 to be followed by a yearly check every 31st of December starting from 31st December 2015

The aggregation process considers most of the account balances that is, Depository, Custodial and so on. However, there are certain accounts,
which are exempt from the process. These exemptions and other rules governing the aggregation are controlled by
FATCA.AGGREGATION.PARAMETER

RELATION.CODE provides the details of related customers, whose balances are considered for aggregation. All the accounts held by the cus-
tomer (except the exempted accounts) are aggregated automatically but this relationship code definition is for aggregating the balance of other
related customers (say, joint owners, same beneficial owner and so on).

Example 1

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 35 of 123
Two US Persons have three accounts between them, one deposit account each and a jointly held deposit account with the following balances:

l US Person A – CIF -100291 : $35,000


l US Person B – CIF - 100292 : $25,000
l Joint Account A and B - CIF - 100293 : $30,000

The joint account is associated with both A and B by reference to a data element in the system. The system shows the account balances for the
accounts. However, the system does not show a combined balance for all the accounts. The fact that the system does not provide a combined
balance does not prevent the aggregations rules applying.

The balance on the joint account is attributable in full to each of the account holders. Considering the above, the aggregate balance for A would
be $65,000 and for B $55,000.

An example of relationship structure is provided below:

There is a relation defined wherein CIF 100292 is related to this CIF as both have the same owner.

In the RELATION CUSTOMER, all these relations are visible:

The reverse relationship is also updated in this table (99) even though no relation code has been defined in Customer record of 100292

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 36 of 123
As per the above example, both 9 and 99 is defined in RELATION CODE field so that the system takes into account, the balances of all the
accounts held by 100291 and 100292 in order to arrive at the aggregated balances for both 100291 and 100292. If only 9 is defined, the aggreg-
ated balance for 100291 is determined by consolidating all the accounts held by both 100291 and 100292. Whereas for 100292, it is only the
balances of all the accounts held by 100292.

As per the regulation, the balance of pre-existing accounts, as on 30th June 2014, needs to be determined taking into account all the account-
s/portfolios held by the user including the joint accounts. In the case of joint accounts, the entire balance of the joint account is attributed to
all the joint holders. In T24, the relationship can be defined at Customer Level (CUSTOMER) or account level (ACCOUNT). If the relationships
are defined at customer level in T24, the RELATION.LEVEL field is to be set as CUSTOMER.

Example 2 : CUSTOMER level relationships

Customer 180501 has two accounts with balances $35000 and $20000 respectively.

Customer 180502 has one account with a balance of $30000.

Customer 180503 (a customer record (CIF) created to represent the joint ownership of 180501 and 180502) has one account with a balance
$10000.

Since a separate CIF is created to record the joint ownership, the balance of all the jointly held accounts is aggregated with the balance of
accounts held individually by the account holders. Based on the above:

l The aggregate balance for customer 180501 is $65000 (including balance of account held by 180503).
l The aggregate balance for customer 180502 is $40000 making it an exempt account (less than $50000).

Example 3 : Account level relationships

Customer 180501 has two accounts with balances $35000 and $20000 (this account held jointly with 180502) respectively.

Customer 180502 has one account with a balance of $30000 based on the above.

The aggregate balance for customer 180501 is $55000 (sum of two accounts).

The aggregate balance for customer 180502 is $50000 including balance of second account held jointly with 180501.

EXCL.FOR.ACC specifies the categories of the accounts that is excluded in deriving the aggregated account balances.

For Example

FATCA.AGGREGATION.PARAMETER

CATEGORY Enrichments Remarks

EXCL.FOR.ACC.1 1011 Pension


Accounts

EXCL.FOR.ACC.2 1012 ISAs Account


Categories
to be
EXCL.FOR.ACC.3 1013 Child Trust excluded in
Funds deriving the
aggregated
accountbal-
EXCL.FOR.ACC.4 1014 Approved SIPs
ances.

Similarly, select portfolios can be excluded from being included in valuation for aggregation purposes. The criteria for specifying the portfolios
to be excluded can be based on any field in SEC ACC MASTER.

The minimum balance requirements for individuals (less than $50000) and entities (less than $250000) are different. The fields in FATCA
AGGREGATION PARAMETER, Ent Cust Field to Ent Cust Val, are used to identify Customers who are legal entities. The fields are associated
and can be multi-valued (multi-values denote ‘or’ condition). In the above example, any client with Industry code as ‘3200’ is considered an
entity and the rest is considered individuals. The operand ‘EQ’ and ‘NE’ can be used here to define the conditions for identifying entities.

As mentioned earlier, the balance check has to be run as part of close of business (COB) on 30th June 2014 for pre-existing accounts with a
yearly review starting from 31st December 2015. Enquiries are available to check:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 37 of 123
l Clients (individuals) with balance less than $50000
l Clients (entities) with balance less than $250000
l High value clients
l Other clients (balance above $50000 for individuals and above $250000 for entities)
l Other clients with US indicia for whom detailed due diligence is required

It is possible to drill down from these enquiries (from Customer ID) and view aggregate balances break-up and also update FATCA record.
While updating FATCA record from the enquiry, the record is pre-populated with the Client Type, FATCA STATUS and Change Reason for
exempt accounts and just the client type for other clients.

The balances can also be checked from FATCA.AGGREGATE.BALANCES.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 38 of 123
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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 39 of 123
FATCA and Customer Relationship
Whenever new FCSI records for individual customers are created, these customers can be linked through a record in
CUSTOMER.RELATIONSHIP application (with RELATIONSHIP.TYPE as ‘Tax’).

Further, this CUSTOMER.RELATIONSHIP record can be linked in any portfolio owned by any of the customers through SEC.ACC.MASTER
application. Whenever this is done, a new record gets created in: FATCA.CUSTOMER.SUPPLEMENTARY.INFO (FCSI) application with IDs
similar to that of the CUSTOMER.RELATIONSHIP record.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 40 of 123
Setup
Creation of a CUSTOMER.RELATIONSHIP record for the two customers created above with Relationship Type as ‘Tax’:

Creation of SEC.ACC.MASTER record 129046-1 and attaching the CUSTOMER.RELATIONSHIP record created above:

The FATCA.CUSTOMER.SUPPLEMENTARY.INFO is auto generated for the portfolio and the ID of that record is the same as that of the ID of
the CUSTOMER.RELATIONSHIP record.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 41 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 42 of 123
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, is 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 43 of 123
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 is the date that the FATCA.STATUS.CONDITION record(s) has changed. The field STATUS.ID is the ID to a record in
the FATCA.STATUS.CONDITION table.

The field FUNCTION is 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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 44 of 123
The record in FATCA.CONDITION.CHANGE has been amended for AFF.TRADE.NFFE. It has changed from ADD to CHG, as shown below:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 45 of 123
FATCA.FCSI.AMENDMENTS

This live file is used to record the FATCA.CUSTOMER.SUPPLEMENTARY.INFO amendment dates for each FATCA customer. This concat file
is updated during the authorisation of the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record. The information is deleted if the
FATCA.CUSTOMER.SUPPLEMENTARY.INFO record is reversed.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 46 of 123
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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 47 of 123
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 is required to institute procedures
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

Notice 2011-34 issued by the IRS in connection with FATCA provides a six step procedure for the determination of US accounts. The following
table is a high level overview of these steps. Refer to the official notice for the in depth explanation.

Step Description

Step 1 Account holders documented as US Persons (provided a W-9 Form) are treated as US accounts. FFI's may elect to treat
as non -US accounts if the aggregated balance or value is less than $50,000.00

Step 2 Accounts with an aggregated balance or value less than $50,000.00 can be treated as non US accounts

Step 3 Private Banking accounts -

A diligent review of electronically available and paper documentation.

Due diligence procedures for accounts with a balance greater than $50,000.00 must be performed within one year from
the effective date of the FFI agreement

For other Private Banking accounts due diligence must be completed by the later of December 31st 2014 or one year from
the effective date of the agreement

Step 4 Accounts with US Indica (not covered by the above steps) the FFI has to review electronically searchable information.
Due diligence must be completed within two years of the effective date of the agreement.

Step 5 High Value accounts with a balance greater than $500,000.00 requires diligent review of the files related to the account.
Due diligence must be completed within two years of the effective date of the agreement

Step 6 Annual retesting of accounts (beginning the third year from the effective date of the agreement)

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 to be US, the account is considered a US account.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 48 of 123
The following chart details the process of an initial assessment for an Entity account.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 49 of 123
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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 50 of 123
How to Configure the FATCA.PARAMETER

Summary: What this How To Shows You 51

Prerequisites 51

Environment 51

Overview 51

Scenario 51

Steps 51

Summary: What this How To Shows You


This How To Guide explains and shows you how to configure the FATCA.PARAMETER for a financial institution who has entered into an
agreement with the IRS.

Prerequisites
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
1. Create a FATCA.PARAMETER record for company GB0010001. In the Admin Menu select Framework
Parameter>Customer> FATCA Admin Menu>FATCA Parameter.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 51 of 123
2. 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 defaults 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 the client has to produce the relevant documentation.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 52 of 123
3. 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 identifies 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 53 of 123
l DEFAULT.RECALCITRANT
l DEFAULT.RECAL.ENTITY
l DEFAULT.DORMANT
l DEFLT.INACTIVE
l DEFLT.US.STATUS
l DEFLT.NON.US.STATUS
4. Authorise the record.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 54 of 123
How to Configure a New FATCA TAX STATUS Record

Summary: What this How To Shows You 55

Prerequisites 55

Environment 55

Overview 55

Scenario 55

Steps 56

Summary: What this How To Shows You


This How To Guide explains and shows you how to enter a new FATCA.TAX.STATUS record.

Prerequisites
The FA module must be installed.

Environment
The screen shots, functionality and workflow are based on a Model Bank 201207 PB.

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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 55 of 123
Steps
1. Enter a new record in the FATCA.TAX.STATUS application. Select Tax Status.

2. Enter the new FATCA.TAX.STATUS ID and select Edit.

3. Enter a description for this record.

4. Authorise the record.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 56 of 123
How to Configure FATCA.STATUS.CONDITION Records

Summary: What this How To Shows You 57

Prerequisites 57

Environment 57

Overview 57

Scenario 57

Steps 58

Summary: What this How To Shows You


This How To Guide shows you how to configure the FATCA,STATUS.CONDITION records, which enables the automatic update of the
FATCA.STATUS.

Prerequisites
The FA module must be installed.

Environment
The screen shots, functionality and workflow are based on a Model Bank 201212 PB.

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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 57 of 123
Steps
1. In the Admin Menu select Framework Parameter>Customer> FATCA Admin Menu>Fatca status condition

2. Enter the ID of the FATCA.TAX.STATUS record that the conditions apply as the @ID to the FATCA.STATUS.CONDITION record.

3. Select the edit button and enter the conditions into the record.
4. Multi value the Decision set of fields. In multi value set 1 enter:
l DECISION FIELD.1 - FORM.TYPE
l DECISION.1 - EQ
l DECISION VALUE.1 - W9
l DECISION FIELD.2 - FORM.TYPE
l DECISION.2 - EQ
l DECISION VALUE.2 - WAIVER
5. Enter a narrative for this:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 58 of 123
6. 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 is auto-
matically set.

It 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.

Refer to the Helptext for more information on these fields.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 59 of 123
How to Use FATCA.CUSTOMER.SUPPLEMENTARY.INFO

Summary: What this How To Shows You 60

Prerequisites 60

Environment 60

Overview 60

Scenario 60

Steps 60

Summary: What this How To Shows You


This How To Guide explains and shows you how to enter FATCA details for a customer, where the FATCA.PARAMETER is configured for
manual classification. The system calculates Indicia and Provenus status.

Prerequisites
The FA module must be installed.

Environment
The screen shots, functionality and workflow are based on a Model Bank 201207 PB.

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
1. Enter the information into a FATCA.CUSTOMER.SUPPLEMENTARY.INFO record.

The id to the record is CUSTOMER.NO.

2. From the User menu, select the FATCA.Details menu and click FATCA Client Info.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 60 of 123
3. Enter the customer number then select the Edit button .

4. 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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 61 of 123
5. 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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 62 of 123
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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 63 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 64 of 123
Fatca - Automatic Update of the FATCA.STATUS in FCSI

Summary: What this How To Shows You 65

Prerequisites 65

Environment 65

Overview 66

Scenario 67

Steps 68

Summary: What this How To Shows You


This How To Guide explains and shows you how the FATCA.STATUS can be automatically updated in the FATCA.SUPPLEMENTARY.INFO
records.

Prerequisites
The Fatca module must be installed and configured.

Environment
The screen shots, functionality and workflow are based on a Model Bank R12.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 65 of 123
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 is tracked, and if these are not received by then, the account classification (FATCA.STATUS) is automatically
updated as part of the batch process.

The automatic update is 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 is 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

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 is 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 66 of 123
Note 3 - If the documents are not received by the cut off date, the status is 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 should be received from all the owners by the cut-off date. Even if
one document is not received, the account is 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
is considered an US_ACCOUNT.

All documents are 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 is 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 meet 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 cannot
be done.

Scenario
The automatic update of the FATCA.STATUS is required for US_ACCOUNTS.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 67 of 123
Steps
1. In the FATCA.PARAMETER record, set the field AUTO.STATUS.UPDATE to Yes.

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

3. Enter the FATCA.CUSTOMER.SUPPLEMENTARY.INFO records for the clients.

Customer 111714

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 68 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 69 of 123
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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 70 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 71 of 123
For Customer 111715, the document details do not meet the requirements; the Account classification has been updated as "No Match Found".
This account is not automatically classified until the Waiver document has been received.

Customer 111716

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 72 of 123
For customer 111716, even though the W9 form has been received and the waiver has been requested, it does not meet the requirements for clas-
sification. The account classification has been updated as no match is found until the waiver details have been entered. Then this can be re-clas-
sified.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 73 of 123
Fatca - Customer Categorisation - Proven Non US

Summary: What this How To Shows You 74

Prerequisites 74

Environment 74

Overview 74

Scenario 74

Steps 74

Summary: What this How To Shows You


This How To Guide shows an example customer being classified as Proven Non US and the subsequent categorisation for FATCA.

Prerequisites
The Fatca Module must be installed and configured.

Environment
The screen shots, functionality and workflow are based on a Model Bank 201207 PB.

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 by 6 March 2015

Steps
1. From the User Menu, select the FATCA Details Menu.
2. Then select Update Fatca Details.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 74 of 123
3. Enter the customer number the select the Edit button .

4. When the record is opened, the system opens a version. Enter the client details in the FATCA Customer Details tab.
5. Based on the customer details entered so far, if the Validate button is selected, the system updates 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 75 of 123
6. 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
regulations on the account. In this example, the customer has been determined as Proven Non US. This means that the customer will
be categorized as NON-US.ACCOUNT.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 76 of 123
The category is entered into the field FATCA.STATUS.

7. Commit and authorise the record.


8. Once validated, the Indicia details are cleared as the account has been classified.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 77 of 123
Fatca - Customer Categorisation - Entity

Summary: What this How To Guide Shows 78

Prerequisites 78

Environment 78

Overview 78

Scenario 78

Steps 78

Summary: What this How To Guide Shows


This How To Guide shows an example categorisation for an entity.

Prerequisites
The FATCA module must be installed and configured.

Environment
The screen shots, functionality and workflow are based on a Model Bank 201207 PB.

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
1. From the User menu select the FATCA Details menu , then select Update Fatca Details -Entity.

2. Enter the customer number the select the Edit button .

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 78 of 123
3. In the FATCA.CUSTOMER.SUPPLEMENTARY.INFO record, enter the above details on the Customer details tab.

4. 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, it has
been classified as Non US Account, as expected.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 79 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 80 of 123
Fatca - Customer Categorisation - Joint Example

Summary: What this How To Shows You 81

Prerequisites 81

Environment 81

Overview 81

Scenario 81

Steps 82

Summary: What this How To Shows You


This How To Guide shows an example categorisation with joint customer details.

Prerequisites
The FATCA module must be installed.

Environment
The Screen shots, functionality and workflow are based on a Model Bank 201207 PB.

Overview
A customer is being assessed using due diligence for FATCA.

Scenario
Another customer called 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 81 of 123
Steps
From the User menu, select the FATCA.Details menu and click Update FATCA  Details.

3. Enter the customer number and click the Edit button .

4. Enter the clients details into the Fatca Customer Details for customer 111661.

5. Enter the document details for the customer.


l Document type of W8BEN
l Received date is today

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 82 of 123
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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 83 of 123
When updated, the classification is updated. As the joint owner is a US ACCOUNT holder, then the classification of customer 111661 is also
now a US account. The specific classification is US ACCOUNT JOINT, as shown below:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 84 of 123
Fatca - Customer Categorisation - Deemed Compliant
Retirement Plan

Summary: What this How To Shows You 85

Prerequisites 85

Environment 85

Scenario 85

Steps 85

Summary: What this How To Shows You


This How To Guide shows you an example of a customer who is automatically classified as a "Deemed compliant Retirement Plan".

Prerequisites
Fatca module must be installed and configured.

Environment
The screen shots, functionality and workflow are based on a Model Bank 201212 PB.

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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 85 of 123
1. From the Fatca Details menu select Update FATCA  Details -Entity.

2. Enter the customer number and Edit the record.

3. Enter the client details in the Entity Details tab.

The field CLIENT.SELF.CLASSIFICATION should be entered. Otherwise, no customer classification will be made. Based on the inform-
ation 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 updates 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

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 86 of 123
4. Enter the document details in the Document Details tab. The following fields are required for classification:
l Document.Type - W9
l Received.Date - todays date

After the record is either validated or committed, the classification details are 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.

5. Authorise the record.

Once the classification has been completed, the Indicia fields are cleared.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 87 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 88 of 123
FATCA Reporting

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 has 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 are required to identify US accounts and report about these accounts to IRS on an annual basis.

Withholding taxes (30%) apply to specified US source income (dividend, interest payments and Original issue discount) 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 US paying agent does not have to withhold 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 compliance with requirements of FATCA.

The Treasury Department has also collaborated with foreign governments to develop two alternative model intergovernmental agreements
(Model 1 IGA and Model 2 IGA) that facilitate the effective and efficient implementation of FATCA in a manner that removes domestic legal
impediments to compliance, fulfils FATCA’s policy objectives, and further reduces burdens on FFIs located in partner jurisdictions. Under the
IGA models, the United States shall not require a Reporting [FATCA Partner] Financial Institution to withhold tax under FATCA provisions
with respect to an account held by a recalcitrant account holder or to close such account. The withholding is applicable only on payments
made to non-participating financial institutions.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 89 of 123
Reporting

The financial institutions have an obligation to Obtain and exchange Information with respect to reportable accounts. This paragraph provides
rules addressing the information reporting requirements applicable to participating FFIs with respect to U.S. accounts.  A participating FFI
shall report by the time and in the manner prescribed in the regulation, the information required with respect to accounts that it is required
under its FFI agreement and the regulation to treat as US accounts maintained at any time during each calendar year. 

1. The name, address, and U.S. TIN of each Specified U.S. Person that is an Account Holder of such account and, in the case of a Non-
U.S.  Entity  that,  after  application  of  the  due  diligence procedures,  is  identified  as  having  one  or more  Controlling  Persons 
that  is  a  Specified  U.S.  Person, the name, address, and U.S. TIN (if any) of such entity and each such Specified U.S. Person;
2. The account number (or functional equivalent in the absence of an account number); 
3. The  account  balance  or  value  (including,  in  the  case  of  a  Cash Value Insurance Contract or Annuity Contract, the Cash Value or
surrender  value) as  of  the  end  of  the  relevant  calendar  year  or other  appropriate  reporting  period  or,  if the  account was
closed during such year, immediately before closure; 
4. In the case of any Custodial Account:  
l The total gross amount of interest, the total gross amount of dividends,  and  the  total  gross  amount  of  other  income gen-
erated with respect to the assets held in the account, in each case paid or credited to the account (or with respect to the
account) during the calendar year or other appropriate reporting period; and 
l The  total  gross  proceeds  from  the  sale  or  redemption  of property paid or credited to the account during the calendar
year  or  other  appropriate  reporting  period  with  respect  to which, the Reporting Financial Institution acted  as  a 
custodian,  broker,  nominee,  or  otherwise  as  an agent for the Account Holder;  
5. In the case of any Depository Account, the total gross amount of interest paid or credited to the account during the calendar year or
other appropriate reporting period; and
6. In the case of any account not described above, the total gross amount paid or credited to the  Account  Holder  with  respect  to  the 
account  during  the calendar year or other appropriate reporting period with respect to which the Reporting  Financial Institution is
the obligor  or  debtor,  including  the  aggregate  amount  of  any redemption  payments  made  to  the  Account  Holder  during  the
calendar year or other appropriate reporting period.

The reporting obligations become effective in a phased manner as shown below:

1. The  information  to  be  obtained  and  exchanged  with  respect  to 2014  is  only  the  information  described  in (1) to (3) above;
2. The  information  to  be  obtained  and  exchanged  with  respect  to 2015  is all of the above ,  except  for  gross  proceeds  described 
in  subparagraph (4); and
3. The  information  to  be  obtained  and  exchanged  with  respect  to 2016  and  subsequent  years  is  all the  information  described 
above.

The address to be reported with respect to an account held by a specified U.S. person is the residence address recorded by the FFI for the
account holder or, if no residence address is associated with the account holder, the address for the account used for mailing or for other pur-
poses by the participating FFI.  In the case of an account held by a U.S. owned foreign entity, the addresses to be reported are the addresses of
both the U.S. owned foreign entity and each substantial U.S. owner of such entity.  

The account number to be reported with respect to an account is the identifying number assigned by the participating FFI for purposes other
than to satisfy the reporting requirements of this regulation or, if no such number is assigned to the account, a unique serial number or other
number such FFI assigns to the financial account that distinguishes the account from other accounts maintained by such institution.  

The FFI shall report the balance or value of the account as of the end of the calendar year. The balance or value of the account is not to be
reduced by any liabilities or obligations incurred by an account holder with respect to the account or any of the assets held in the account and
is not to be reduced by any fees, penalties or other charges to which the account holder is liable for terminating, transferring, surrendering,
liquidating, or withdrawing cash from the account. 

The account balance or value of an account may be reported in U.S. dollars or in the currency in which the account is denominated.  In the case
of an account denominated in a foreign currency, if the FFI elects to report account balances or values in the currency in which the account is
denominated, it is required to identify the currency in which the account is reported.  If the FFI elects to report such an account in U.S. dollars,
the FFI must calculate the account balance or value of the account by applying a spot rate to translate such balance or value into the U.S.
dollar.  The spot rate must be determined as of the last day of the calendar year or, if the account was closed during such calendar year, the clos-
ure dates of the account.  

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 90 of 123
In the case of a US account closed or transferred in its entirety by an account holder during a calendar year, that is a financial account described
under the relevant sections, the FFI is required to report the account as closed or transferred along with the amounts. 

If a FFI retains copies of account statements with respect to holders of U.S. accounts in the ordinary course of its business, such statements
must be provided to the IRS within 30 days of a request for such statement to the extent they have been retained under such business pro-
cedures at the time of the request.  AFFI is required to retain for six years copies of account statements that summarize the activity in the
account for each calendar year for which the account is required to be reported under the regulation and is required to provide such copies to
the IRS within 30 days of a request for such statements.      

Reporting of Recalcitrant Account Holders


A FFI, as part of its reporting responsibilities under its FFI agreement, shall report for each calendar year, the following groups of account hold-
ers separately:

1. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year, other than
accounts  that have U.S. indicia;
2. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year, other than
accounts described above, that do not have U.S. indicia ; and 
3. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year that are
dormant accounts.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 91 of 123
Reporting Parameter

FATCA REPORTING PARAMETER is used to specify the high level parameters governing the yearly reporting required under FATCA.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 92 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 93 of 123
Field Name Description

@ID The Company ID is the ID for this record. Parameter setup for the company is defined here

REP.EXTRACT.DATE Denotes the date on which the base data for reporting is extracted and consolidated in the FA.REPORT.BASE
file. The COB runs on the set date to update the base file with the ‘base’ data for all users. It is recommended to
set the date to 31st December of the year always. If the set date is a holiday, the extraction is on previous work-
ing day. The account balances are always updated on the last working day of the calendar year. This is recycled
to the next date when the base update for a year is done.

REPORTABLE.STATUS Identifies the status which is to be reported to the regulator. The base file records are built based on these
status only.

OWN.REP.STATUS Displays the statuses for which the owner (beneficial and substantial) details are to be reported. For the
accounts where the owner details are to be reported based on the status (classifications) defined here, the sys-
tem extracts the details of beneficial and substantial owners (as applicable) and updates the base file. The bene-
ficial and substantial owner roles are identified based on roles defined in FATCA ROLE TYPE. As per the Form
8966 reporting, this is required for OD FFIs and Passive NFFEs with identified US owners.

STATUS.TYPE Identifies the various classifications that falls under RECALCITRANT/NONPARTICIPATING/ DORMANT
/INACTIVE/PASSIVE_NFFE/OD_FFI/SPEC_US_PERSON category (only values allowed). The field is in con-
junction with FATCA.STATUS.

FATCA.STATUS Identifies the recalcitrant, non-participating, dormant or any of the statuses above. All the statuses that are to
be reported needs to be included in Reportable Status as well. The field is associated with STATUS.TYPE.

DEFAULT.ADDRESS Specifies whether the address of the user must be from CUSTOMER or DE.ADDRESS.

ADDRESS.RECORD If the DEFAULT.ADDRESS is set to DE.ADDRESS, the DE.ADDRESS record from where the address of the cus-
tomer is picked up. For example, if the ADDRESS.RECORD is set as PRINT.1, for customer ID (100252) in
Company 1 (GB0010001), the system will read the DE ADDRESS record GB0010001.C-100252.PRINT.1 and
gets the address. If there is no matching in DE.ADDRESS record, then there are no default.

OWNER.TYPE Specifies the type of the owner (JOINT, BENEFICIAL or SUBSTANTIAL).

REL.IDENTIFIER If set to FCSI, the related customers are identified from the FCSI record. If left blank, the related customers is
from the Customer or Account (based on Relation level defined in FATCA.AGGREGATION.PARAMETER). For
beneficial and substantial ownership, the relationships are only from the FCSI; whereas for joint owners the rela-
tionships can be at FCSI level or customer or account level. So, if the OWNER TYPE is Beneficial or substantial,
only FCSI is allowed.

REL.CODE If the REL.IDENTIFIER field is left blank, the relation codes that are used for the identifying the owners in
OWNER TYPE is taken. This field specifies the multiple relation codes. This field must be be left blank, if
REL.IDENTIFIER is set as FCSI. This field is only used for defining relation codes for joint owners, if the rela-
tionships are not defined in FCSI or in FATCA.AGGREGATION.PARAMETER.

OWNER.ADDRESS Specifies whether the address of the owner type (defined above) is to be from CUSTOMER, FCSI or
DE.ADDRESS. If no Customer record exists for the owner specified in FCSI, the address is from FCSI irre-
spective of the settings done in this field.

OWNER.ADD.RECORD If the OWNER.ADDRESS is set to DE.ADDRESS, the DE ADDRESS record from where the address of the
owner is picked up. For example, if the OWNER.ADD.RECORD is set as PRINT.1, for customer ID (100252) in
Company 1 (GB0010001), the system reads the DE.ADDRESS record GB0010001.C-100252.PRINT.1 and
gets the address. If there are no matching for the DE.ADDRESS record, then the value is not defaulted.

COUNTRY.SUB.ENTITY This field is one of the elements that needs to be part of FATCA reporting (XML schema). The field from where
this data is obtained (can be a field in Customer or DE.ADDRESS – core or local) is defined here.

FCY.ACC.REPORT If the non-US currency accounts is to be reported in the currency in which they are denominated, this field is to
be set as ACCOUNT. Alternatively, if they are to be reported in USD, this field is to be set as USD. By default,
all accounts are reported in USD. For portfolios, if the accounts are to be reported in the currency in which they
are denominated, the system reports in the reference currency.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 94 of 123
RECAL.REPORT If a pool report is to be prepared for the aggregated balances of recalcitrant accounts (recalcitrant, recalcitrant
with indicia, dormant, dormant with indicia), the field must be set to YES. The system updates
FATCA.RECAL.POOL.BALANCE with the aggregated balance of such accounts. The pool report is for FATCA
STATUS defined above (associated with STATUS TYPE field except PASSIVE_NFFE, OD_FFI and SPEC_US_
PERSON).

NPFFI.REPORT Aggregate reporting on non-participating (NPFFI) payments is not required in 2014. So, the field is set as NO in
2014 and changed in 2015. The FATCA.POOL.BALANCE for NPFFIs is not updated if this field is set as NO.

MIN.BAL.CHECK If this field is set to YES, the accounts with balance less than $50000 (as on closure date or year-end date) is
excluded from reporting. The base record is not built for such accounts.

AGG.BAL.CHECK If this field is set to YES, the minimum balance check as above is applied only if aggregate balance (total of
either custody or depository accounts) is below $50000. If not, all the accounts are reported. If this field is left
blank, then the minimum balance check is based on individual accounts.

BASE.RETENTION Indicates the number of years for which the data on base file needs to be retained. If set to six, the 2014 base
data is retained till the end of 2020.

UPDATE.INC.BASE If the withholdable income (FDAP from 2014 and gross proceeds from 2017) needs to be updated in base, then
set this field to YES.

NEW.ACCOUNT.ONLY If this field is set to YES or 2014, then only those accounts opened after 1st July 2014 are included in the base
file.

NEW.ACCOUNT.ENT If this field is set to YES, the accounts for entities opened till 1st Jan 2015 are considered pre-existing and are
not included in the base file.

NEW.ACC.EXIST If a new account is opened for an existing user, then this field controls all the accounts of the users which must
be included in base or only the accounts opened after 1st July 2014. If this field is set to YES, it include all the
accounts. If set to NO, the accounts included are based on NEW.ACCOUNT.ONLY.

XML.DIR Defines the name of the directory used to hold XML messages. The UNIX or NT path name for the directory can
be specified with '/' separators.

HMRC.SCHEMA Indicates the UK specific schema.

FATCA.ID Stores the FATCA ID (assigned to the bank by HMRC).

DUE.DILIGENCE.IND Indicates whether an account is a Reportable Account or an account held by a Non-participating Financial Insti-
tution.

THRESHOLD.IND Indicates thresholds in the due diligence process.

Since only specific clients need to be reported, the reportable statuses (based on FATCA STATUS of the client in FATCA CUSTOMER
SUPPLEMENTARY INFO) are specified here. Besides, for certain clients (Passive NFFEs, Owner Documented FFIs), the details of substantial
and beneficial owners also need to be reported. The statuses for which the ownership details need to be reported are also defined in FATCA
REPORTING PARAMETER.

Specified US Persons, Passive NFFEs, Owner Documented FFIs, Recalcitrant and dormant statuses are identified based on the FATCA
STATUS associated with each of these status types.  The reporting will vary based on the type above (for e.g. substantial owner details need to
be reported for Passive NFFEs, recalcitrant accounts may be subject to pool reporting).

Besides, the parameter is also used to specify default address to be used for reporting (CUSTOMER or DE ADDRESS), whether pool reporting
is required for recalcitrant clients, whether accounts are to be reported in account currency or USD and whether accounts with balance less
than USD 50000 needs to be reported or not.

Banks/financial institutions are expected to report annually with the first reporting due in 2015 (for 2014 year end balance). As part of the
Close of Business on the report extraction date (as per the date specified in parameter – the last working day of the calendar year), a record will
be built in FATCA TAX BASE for all the reportable clients.

For closed accounts, the base needs to be updated on the date the closure notice is received from the client. When a client gives notice for clos-
ure (closure of the relationship with the bank), FATCA STATUS needs to be updated manually by the users in FATCA CUSTOMER
SUPPLEMENTARY INFO. The status needs to be the same as FATCA STATUS defined for ‘Inactive’ status type in FATCA REPORTING

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 95 of 123
PARAMETER. As part of the COB on that day, FATCA TAX BASE will be updated with the details of the client and his account balances (as on
date).

Only the accounts of reportable clients (US accounts, Passive NFFEs, etc.) needs to be reported when closed. In order to cater to this, it is
advised to use separate FATCA STATUS for reportable closures and non-reportable closures (e.g. non-US account).

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 96 of 123
FATCA TAX BASE

FATCA TAX BASE is a live file (ID: Customer.YYYYMMDD) that has all the data that needs to be reported – Customer name, address,
TIN/EIN/GIIN details, ownership details (passive NFFEs, Owner documented FFIs), client type and account balance details (in 2015, the
2014 year end account balance is reported) including details of accounts (and portfolios) in which the client is a joint owner.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 97 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 98 of 123
In the case of Passive NFFEs with US substantial owners, the substantial owner details are also be updated in the base.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 99 of 123
The following fields are updated from the FSCI record:

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 100 of 123
l CLIENT.TYPE
l US.PLACE.OF.BIRTH
l CITIZENSHIP
l GREENCARD
l TAX.RESIDENCE (If not present in FCSI record, taken from the RESIDENCE field in CUSTOMER)
l TIN.COUNTRY
l TIN.CODE
l EIN
l SOCIAL.SEC.NO
l GIIN (If GIIN is blank, corresponding FORM ID is the GIIN.)
l SPONSOR.GIIN
l SELF.CLASS (Entity Status)
l REL.CUST.NAME.2 (The last name updated from FCSI)
l REL.ALIAS (This is updated from the FCSI for the related customer)
l ROLE.TYPE
l REL.NATIONALITY
l REL.RESIDENCE
l REL.STREET (1st line of Address Multi-value associated with the owner in FCSI – Role Type multi-value)
l REL.ADDRESS (2nd line of Address Multi-value associated with the owner in FCSI – Role Type multi-value)
l REL.TOWN.COUNTRY (3rd line of Address Multi-value associated with the owner in FCSI – Role Type multi-value)
l REL.POST.CODE (4th line of Address Multi-value associated with the owner in FCSI – Role Type multi-value)
l REL.COUNTRY (Holder Address Country)
l REL.CNTY.SUB.ENT (5th line of Address Multi-value associated with the owner in FCSI – Role Type multi-value)
l REL.BIRTH.DATE
l REL.OWN.PERC
l REL.CUST.TIN
l REL.ADDR.COUNTRY
l REL.TIN.COUNTRY
l REL.ENTITY.TYPE
l STATUS.NARRATIVE
l STATUS.CHANGE.DATE

The following fields are updated from the CUSTOMER record:

l NAME.1
l NAME.2
l SHORT.NAME
l SECTOR
l INDUSTRY
l CUSTOMER.STATUS
l NATIONALITY
l RESIDENCE

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 101 of 123
l DOMICILE
l BIRTH.INCORP.DATE

The following fields are updated from the CUSTOMER or DE.ADDRESS record:

l STREET
l ADDRESS
l TOWN.COUNTRY
l POST.CODE
l COUNTRY

The following fields are updated from the Account or Portfolio record:

l ACCOUNT.OFFICER

Field Name Description

@ID Indicates the CUSTOMER.DATE (customer * extraction date).

STATUS.DATE Indicates the date on which, the base file is updated. This is taken from the ID of this application.

BASE.YEAR Indicates the year to which the base data pertains to. This is extracted from the date in the ID.

COUNTRY.SUB.ENTITY Updated from Customer or DE.ADDRESS field based on reporting parameter setting.

COMPANY.BOOK Indicates the COMPANY of the account or portfolio.

RELATION.CUST Updated with FATCA.STATUS equal to the Owner Report Status in FATCA Reporting Parameter. Customer ID
or Unique ID from FCSI is updated.

RELATION.CODE Indicates the relation code for the associated Related Customer. It is blank if relationship details are being
updated from FCSI.

REL.CUST.NAME.1 Indicates the name of the related customer. It is the first name, if the first name is present elsewhere then it is
the holder name.

REL.FATCA.STATUS Updated from JO.BO.STATUS

INDICIA Updated as YES, if Indicia Strength is not blank.

FATCA.STATUS Updated from the FATCA.STATUS of the user.

STATUS.TYPE Updated from the status type for the associated FATCA.STATUS from the FATCA.REPORTING.PARAMETER
record.

ACCOUNT Indicates the account number or the portfolio ID or the contract to which the balance pertains to.

ACC.OPEN.DATE Indicates the date of opening of the account or portfolio.

ACCOUNT.TYPE Updated as Depository or Custody.

ACCT.PORT.CCY Indicates the currency of the account or portfolio to be reported.

ACC.BALANCE Indicates the Balance of the account/portfolio in account/portfolio currency.

ACC.EXCH.RATE Indicates the exchange rate used to convert the balance to USD.

ACC.BAL.USD Indicates the balance in USD.

TOT.ACC.BAL.DEP Indicates the total balance of all depository accounts.

TOT.ACC.BAL.CUST Indicates the total balance of all custody accounts.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 102 of 123
EXISTING.NEW Updated as EXISTING, if the customer is pre-existing or updated as NEW.

FI.RETURN.REF Indicates the reference ID (FATCAID, ReportingPeriod, Jurisdiction).

FI.RETURN.ACTION Holds a valid value of New, Replacement and Variation.

DUE.DILIGENCE.IND Indicates whether an account is a Reportable account or an account held by a Non-participating Financial Insti-
tution.

THRESHOLD.IND Indicates thresholds in the due diligence process.

FI.REGISTER.ID Indicates the first three digits of the FI’s name.

TIN.CODE.TYPE In the case of individuals where TIN is being reported, the TIN CODE TYPE is updated as ITIN. In the case of
entities, where EIN is present, the field is updated as EIN. If GIIN is present, the field is updated as ‘Other’.

FATCA.USER.ID Indicates the FATCA.ID (assigned to the bank by HMRC), which is populated from
FATCA.REPORTING.PARAMETER record.

All the accounts (except accounts that are specifically excluded, accounts/deposits, portfolios with balance or value less than $50000 based
on parameter setting) is included in the base file for the balance to be reported. The accounts that are jointly held (identified based on settings
in FATCA AGGREGATION PARAMETER and relationships defined in CUSTOMER/ACCOUNT) are also be reported as the balance of jointly
held accounts and need to be attributed to all the account holders.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 103 of 123
POOL REPORTING

A FFI, as part of its reporting responsibilities under its FFI agreement, shall report for each calendar year, the following groups of account hold-
ers separately:

1. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year, other than
accounts  that have U.S. indicia;
2. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year, other than
accounts described above, that do not have U.S. indicia ; and 
3. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year that are
dormant accounts. 

A consolidated record with the pool balance will be built for clients that are classified as Recalcitrant or Dormant, provided pool reporting is
required (RECAL REPORT field in FATCA REPORTING PARAMETER).

The aggregated balance will be updated at year end based on the balances from FATCA TAX BASE and updated in FATCA POOL BALANCE.

Field Name Description

@ID Indicates the COMPANY_ID.STATUS_TYPE.INDICIA.YEAR (Company id * Status Type * Indicia * Year).

STATUS.TYPE Updated from the the FATCA.TAX.BASE record, extracted from the ID.

YEAR Indicates the year to which the aggregated balance pertains to.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 104 of 123
NO.COUNT Indicates the number of accounts under the above status type. The Count is by number of users ignoring related
customers.

ACC.BALANCE Indicates the balance in USD. The balance is aggregated from FATCA.TAX.BASE.

FI.RETURN.REF Indicates the reference ID (FATCAID, ReportingPeriod, Jurisdiction).

FI.RETURN.ACTION Holds a valid value of New, Replacement and Variation.

DUE.DILIGENCE.IND Indicates whether an account is a Reportable Account or an account held by a Non-participating Financial Insti-
tution.

THRESHOLD.IND Indicates thresholds in the due diligence process.

FI.REGISTER.ID Indicates the first three digits of the FI’s name.

FATCA.USER.ID Indicates the FATCA.ID (assigned to the bank by HMRC) which is populated from
FATCA.REPORTING.PARAMETER record.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 105 of 123
Form 8966

Form 8966 is to be filed by those listed under ‘Who Must File’ below, including Participating FFIs, registered deemed-compliant FFIs, and
Reporting Model 2 FFIs, to report the U.S. account and other account information required as a condition of their applicable status.  For the
2015 and 2016 years, Form 8966 is also to be filed by FFIs to report foreign reportable amounts paid to their account holders that are non-
participating FFIs. Form 8966 is further to be filed by a withholding agent to report U.S. owners of certain foreign entities regarding with hold-
able payments made to these entities.

Who Must File


Except as otherwise provided, you are required to file Form 8966 if you are one of the following persons: 

l Participating FFI (PFFI) or branch

A PFFI must file Form 8966 to make a report as further described in Accounts and Amounts Subject to Reporting on Form 8966 below. 

l U.S. branch of a PFFI Not Treated as a U.S. Person

A  U.S. branch of a PFFI that is not treated as a U.S. person, and that has not elected chapter 61 reporting, is subject to the same Form 8966
reporting requirements as a PFFI.

l Registered-Deemed Compliant FFI (RDC FFI)

An RDC FFI reports on Form 8966 under the requirements applicable to a PFFI with respect to those of its accounts for which it has reporting
obligations as a condition of its applicable RDC status.

l Limited branch or FFI

A Limited branch or FFI reports on Form 8966 under the requirements of a PFFI to the extent permitted under the relevant laws pertaining to
the branch or FFI. 

l Reporting Model 2 FFI

A Reporting Model 2 FFI reports on Form 8966 under the requirements applicable to a PFFI, subject to the provisions of its Model 2 IGA and
its FFI agreement, such as permission to include certain non-consenting U.S. accounts in pooled reporting for recalcitrant account holders. 

l Qualified Intermediary (QI), Withholding Foreign Partnership (WP), Withholding  Foreign Trust (WT)

A QI, WP, or WT reports on Form 8966 as provided in its QI, WP, or WT agreement and in accordance with the entity’s applicable chapter four
status (such as a PFFI or direct reporting NFFE).

l Direct reporting NFFE

A direct reporting NFFE reports on Form 8966 regarding certain U.S. owners of the entity, with respect to certain with-holdable payments
made to the entity.

l Sponsoring Entity

A Sponsoring Entity reports on Form 8966 on behalf of a Sponsored Entity to the extent and in the manner required as if such Sponsoring
Entity were a PFFI, or a direct reporting NFFE, with respect to the accounts maintained by, or withholdable payments made to, the sponsored
FFI or direct reporting NFFE. 

l Withholding Agent 

A withholding agent reports on Form 8966 regarding certain U.S. owners of certain foreign entities to whom it makes with-holdable payments.

Form 8966 is not required to be filed for the circumstances described below.

l U.S. withholding agent reporting payments to U.S. persons 

Report these payments on the appropriate Form 1099 to the extent required under chapter 61. Do not file Form 8966 to report these pay-
ments.

l Reporting Model 1 FFI 

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 106 of 123
A Reporting Model 1 FFI (other than certain U.S. branches treated as U.S. persons, see below, and branches treated as participating FFIs or
reporting Model 2 FFIs) does not file Form 8966 with the IRS.  A Reporting Model 1 FFI reports any information required to be reported under
a Model 1 IGA to the applicable Model 1 IGA tax authorities.

l FFIs Reporting under Chapter 61

An FFI that is not required to file Form 8966 to report a payment to a U.S. person under chapter 4, may be required to report under chapter 61,
such as regarding an account that a PFFI does not elect to report instead as a U.S. account. 

l PFFI Electing Form 1099 Reporting 

A PFFI that elects Form 1099 reporting is not required to report with respect to an account to which such election applies held by a specified
U.S. person.  See Regulations section 1.1471-4(d)(5).

l Sponsored FFI or Sponsored direct reporting NFFE

A Sponsored FFI, or a Sponsored direct reporting NFFE, does not file Form 8966.  The FFI’s, or direct reporting NFFE’s, Sponsoring Entity
files Form 8966 on behalf of the Sponsored Entity.  See Regulations 1.1471-4(d)(2)(ii)(C).

l Withholding Agent

A withholding agent generally reports chapter 4 reportable amounts on Form 1042-S and not on Form 8966, except for reporting regarding cer-
tain U.S. owners of certain foreign entities to whom with-holdable payments are made.  See Regulations section 1.1474-1(d), 1.1474-1(i), and
Form 1042-S and instructions.

l U.S. branch of a PFFI, Reporting Model 1 FFI, Reporting Model 2 FFI, or Territory financial institution, treated as a U.S. person 

A U.S. branch of a PFFI, Reporting Model 1 FFI, Reporting Model 2 FFI, or Territory financial institution that is treated as a U.S. person
reports in the same manner as a Withholding Agent above with respect to with-holdable payments to U.S. persons. See Regulations section
1.1471-1(b)(122), 1.1471-1(b) (126), 1.1471-4(d)(2)(ii)(B), and 1.1471-4(d)(2)(iii)(B).

How and When to File

When to file

Form 8966 is required to be filed for the 2014 calendar year on or before March 31, 2015. 
Extension of time to file - There is an automatic 90-day extension of time to file Form 8966. 

Under certain hardship conditions, the IRS may grant an additional 90-day extension to file Form 8966.  A request for an additional 90-day fil-
ing extension due to hardship must contain a statement setting out the reasons for requesting the extension. 

How to File
Electronic Filing requirement. A PFFI, a RDC FFI, Reporting Model 2 FFI, or a withholding agent that is a financial institution is required to file
Form 8966 electronically unless it has requested and received a waiver of the electronic filing requirement from the IRS for filing this form. The
form can be electronically filed through the IRS’s FATCA website at www.irs.gov/fatca.

PFFI Reporting
Reportable Accounts.  A PFFI must file a separate Form 8966 for each reportable account, or for each group of accounts for which, pooled
reporting is permitted, in accordance with its FFI agreement and Regulations section 1.1471-4(d), including for each:

l U.S. Account that is any financial account that it maintains that is held by one or more specified U.S. persons or U.S. owned foreign
entities.  It has to be filed separately for each account held by a specified U.S. person, and for each substantial U.S. owner of an
account held by a passive NFFE that is a U.S. owned foreign entity.
l Account held by an Owner-documented FFI (ODFFI) as defined in Regulations section 1.1471-5(f)(3).  File a separate Form 8966 to
report for each specified U.S. person that owns certain equity or debt interests in the ODFFI in accordance with Regulations section
1.1471-3(d)(6)(iv)(A)(1) and (2). See Regulations section 1.1471-3(d)(6)(iv)(A)(1) and (2), and 1.1471-4(d)(2)(iii)(D).
l Account held by a Territory financial institution not treated as a U.S. person.  File a separate Form 8966 with respect to each sub-
stantial U.S. owner of a foreign entity that is a passive NFFE with respect to which the territory financial institution acts as an inter-
mediary and provides the PFFI with the information and documentation required under  Regulations section 1.1471-3(c)(3))(iii)(G). 
See 1.1471-4(d)(2)(ii)(B)(2).

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 107 of 123
l Account held by a Nonparticipating FFI.  For calendar years 2015 and 2016, file a separate Form 8966 for each account maintained
for a nonparticipating FFI (including a limited branch or limited FFI treated as a nonparticipating FFI) to report certain aggregate
amounts.   See below for permitted pooled reporting for non-consenting nonparticipating FFIs, if specific payee reporting is pro-
hibited under domestic law without the account holder consent.
l Group of Accounts for which Pooled Reporting is Permitted

Accounts of the following Pooled Reporting Types may be reported on a single Form 8966: Recalcitrant account holders with U.S. indicia,
Recalcitrant account holders without U.S. indicia, Recalcitrant account holders that are U.S. persons, Recalcitrant holders that are passive
NFFEs, and Recalcitrant account holders of Dormant Accounts.  A Reporting Model 2 FFI, under the terms of the Model 2 IGA, is required to
report certain aggregate information regarding accounts it is required to treat as non-consenting U.S. accounts on Form 8966 in the manner
described in §1.1471-4(d)(6).     For calendar years 2015 and 2016, if specific payee reporting is prohibited under domestic law without account
holder consent, the pool of non-consenting nonparticipating FFIs may be reported on a single Form 8966.

l Report Accounts Maintained at Any Time During Calendar Year

Report with respect to any of the above accounts maintained at any time during each calendar year, including accounts that are identified as
U.S. accounts by the end of such calendar year pursuant to a change in circumstances during such year.

Information to be Reported
The information is to be reported includes the following:

l Account held by specified U.S. persons.  Identification of the account holder (name, address, and TIN), account number, account bal-
ance or value, certain enumerated payments with respect to the account, and such other information as may be required. See Regu-
lations section 1.1471-4(d)(3)(ii).
l Account held by Passive NFFE.  With respect to a passive NFFE that is a U.S. owned foreign entity, on a separate Form 8966 for
each, a substantial U.S. owner, identification of the NFFE and substantial U.S. owner (name, address, and TIN), account number, 
account balance or value, certain enumerated payments with respect to the account, and such other information as may be required.
See Regulations section 1.1471-4(d)(3)(iii).
l Account held by ODFFI.  With respect to each account held by an ODFFI, on a separate Form 8966 for each specified U.S. person
that owns certain equity or debt interests in the ODFFI in accordance with Regulations section 1.1471-3(d)(6)(iv)(A)(1) and (2), iden-
tification of the ODFFI and specified U.S. person (name, address, and TIN), account number, account balance or value, certain enu-
merated payments with respect to the account, and such other information as may be required. 
l Account held by nonparticipating FFI.  For calendar years 2015 and 2016, with respect to each account held by a nonparticipating
FFI (unless pooled reporting is permitted), identification of the account holder, account number, account balance or value, certain
enumerated foreign reportable payments (unless an election is made to report all payments made) with respect to the account, and
such other information as may be required.
l Pooled Reporting.  For each group of accounts for which, pooled reporting is permitted, the aggregate number of accounts and the
aggregate account balance or value.  See Regulations section 1.1471-4(d)(6).
l Amount and character.  The amount and character of payments made with respect to an account may be determined under the same
principles that the PFFI uses to report information on resident account holder to its domestic tax authority.  Thus, the amount and
character of items of income required to be reported need not be determined in accordance with U.S. federal tax principles.  If any
type of payment is not reported to domestic tax authorities, such amounts may be determined in the same manner as used for report-
ing to the account holder.  Otherwise, reporting must either be in accordance with U.S. federal tax principles, or with any reasonable
method consistent with the accounting principles applied by the PFFI.  IRS consent is required to change such method, except that a
change to rely on U.S. federal income tax principles is automatically permitted.  See Regulations section 1.1471-4(d)(4)(iv)(E).

Currency Translation
Account balance or value, and any reportable payment, may be reported in U.S. dollars or in the currency in which the account or payment is
denominated.  In the case of an account, or payments denominated in multiple currencies, the PFFI may elect to report the account balance or
value, or payments, in a currency in which the account or payments are denominated and is required to identify the currency, including the
applicable currency code, in which the account is reported. 

Transitional Reporting for 2014 and 2015


l 2014 calendar year.  Report all the foregoing information, except for the enumerated payments with respect to the account. 

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 108 of 123
l 2015 calendar year.  Report all the foregoing information, except for such enumerated payments with respect to the account consisting
of certain gross proceeds. 

Form 8966 – Paper Filing


There are five parts to Form 8966.  A filer completes only the relevant parts of the form applicable for that filer, as follows:

FILER SEPARATE FORM 8966 FOR EACH COMPLETE


PARTS

PFFI l U.S. account held by a specified U.S. person (unless pooled reporting for recalcitrant accounts is I, II, and IV
applicable)

l Substantial U.S. owner of each U.S. account held by a passive NFFE (unless pooled reporting is I, II, III, and
applicable) IV

l Specified U.S. person owner of certain equity or debt interests in an ODFFI account holder I, II, III, and
IV

l Nonparticipating FFI held account (unless pooled reporting is applicable) I, II, IV

l Type of pooled reporting accounts I and V

WITHHOLDING l Specified U.S. person owner of certain equity or debt interests in an ODFFI account holder or payee I, II, III, and
AGENT recipient of a with-holdable payment IV

l Substantial U.S. owner of each U.S. account held by a passive NFFE, or of each passive NFFE that is I, II, III, and
a or payee recipient of a with-holdable payment IV

Part I – Identification of Filer


Complete Part I to provide identifying information about the Form 8966 filer.  All filers must complete lines 1 through 3 (c).  Filers provide
information on lines 4 and 5 as required by the specific instructions below, for those lines. 

Lines 1 through 3b.  Enter the filer’s name and mailing address, including country and postal code.  If your post office does not deliver mail to a
street address, and you have a post office box, enter your post office box number instead of your street address.

Line 3c.  If the filer is a PFFI, Reporting Model 2 FFI, or an RDC FFI, report the country of the branch that maintains the account reported in
Part II, if different from the FFI’s country of residence.  Otherwise, report the filer’s country of residence. 

Line 4.  If the filer has been assigned a GIIN by the IRS, enter it on line 4.  Use the GIIN of the branch that maintains the account, if different. 
Where a Sponsoring Entity is filing on behalf of a Sponsored FFI or a Sponsored direct reporting NFFE, use the GIIN of the Sponsoring Entity.

Line 5.  If the filer has been assigned a taxpayer identification number (TIN) by the IRS, enter it on line 5.  A QI, WP, or WT enters on line 5
the EIN that was issued by the IRS to be used by the QI, WP, or WT when acting in its capacity such.  You are not required to obtain a U.S.
TIN in order to file Form 8966 if you have not been issued a TIN. 

Lines 6 through 10.   Enter the information required by lines 6 through 10 to report the indicated information relating to:

l A Sponsored FFI on behalf of which a Sponsoring Entity is filing Form 8966.


l A Sponsored direct reporting NFFE on behalf of which, a Sponsoring Entity is filing Form 8966
l A Territory financial institution, not treated as a U.S. person, on behalf of which a filer is filing Form 8966.

Follow the instructions for lines 1 through 3c to provide the information required by lines 6 through 8c.

Line 9.   If the entity reported on line 6 is a Sponsored FFI that is an RDCFFI, the Sponsored FFI’s GIIN must be entered on line 9.    If the
entity reported on line 6 is a Sponsored direct reporting NFFE, the direct reporting NFFE’s GIIN must be entered on line 9.  If a Territory fin-
ancial institution is reported on line 6, [determine identifying number to be provided].

Line 10.   If the entity shown on line 6 has been issued a TIN, enter the TIN on line 10.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 109 of 123
Part II - Account Holder or Recipient Information
On a separate Form 8966 for each reportable account or payee recipient, or for each of certain U.S. owners of the ODFFI or NFFE indicated by
checking the relevant box on line 5, complete Part II to report information concerning the account holder, or payee of with-holdable payments,
as follows.

Caution/tip.  Jointly hold accounts.  If a jointly held account is being reported in Part II, you must report each account holder that is a spe-
cified U.S. person on a separate Form 8966. 

Lines 1 through 5.   Enter the following information for each account holder or payee. 

Line 1.  Enter the name of the account holder or payee. 

Lines 2 through 3c.   Enter the account holder’s or payee’s address, including country and postal code, on lines 2 through 3c, as follows.  If a
residence address cannot be reported as required, report the address used for account or payee mailings by the FFI or withholding agent.

Line 3c.  If you are reporting an address in the United States, enter only the 9 digit zip code (zip + 4) for that address.

Line 4.  Enter the social security number (SSN), individual taxpayer identification number (ITIN), or employer identification number (EIN) for
an account holder or payee that is a specified U.S. person. 

Line 5.   Check the appropriate box on line 5 that describes the account holder or payee recipient reported in Part II, line 1.  

Part III – Identifying Information of U.S. Owners that are specified U.S. Persons
Lines 1 through 4.   Enter the following information for the subject of the reporting on the form. 

l If you are reporting an account held by, or a payment made to, a specified U.S. person, enter the account holder’s or payee‘s residence
address recorded by the FFI. 
l If you are reporting an account held by, or a payment made to, a passive NFFE with a substantial U.S. owner, enter the residence
address for such substantial U.S. owner.   If a passive NFFE has more than one substantial U.S. owner, report each substantial U.S.
owner on a separate Form 8966.
l If you are reporting an account held by, or payment made to, an ODFFI, enter the residence address of each specified U.S. person 
that owns certain equity or debt interests in the ODFFI in accordance with Regulations section 1.1471-3(d)(6)(iv)(A)(1) or (2).   If
there is more than one such specified U.S. person with respect to an ODFFI, file additional Forms 8966 to report each such specified
U.S. person. 

Line 3c.  If you are reporting an address in the United States, enter only the 9 digit zip code (zip + 4) for that address.

Line 4.  Enter the social security number (SSN), individual taxpayer identification number (ITIN), or employer identification number (EIN) for
the subject of the reporting on the form.

Part IV – Financial Information


Lines 1 through 4.   Enter the indicated financial information for the subject of the reporting on the form. 

Part V – Pooled Reporting Type


Lines 2 through 5.   Enter the information for the applicable pooled reporting type, subject of the reporting on the form, corresponding to the
box that you check on line 1.  If an account balance or payment is reported in U.S. dollars, the PFFI must calculate the amount in the manner
described in Regulation section 1.1471-5(b)(4).

A FFI, as part of its reporting responsibilities under its FFI agreement, shall report for each calendar year, the following groups of account hold-
ers separately:

1. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year, other than
accounts  that have U.S. indicia
2. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year, other than
accounts described above, that do not have U.S. indicia
3. The aggregate number and aggregate value of accounts held by recalcitrant account holders at the end of the calendar year that are
dormant accounts. 

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 110 of 123
Electronic Filing – Schema Instructions
The preceding section covered the instructions applicable for paper filing of Form 8966. This sections contain the guide
(instructions) for electronic filing.

FATCA XML
This section explains the information required to be included in each data element of the FATCA XML schema and its mapping to fields in
T24.    Where a data element is not used for FATCA reporting, the same has been excluded.

The requirement field for each data element and its attribute indicates whether the element must be included in the schema (mandatory or val-
idation), is optional, or is not used for FATCA (null).  The following terms are used:

l Validation – The data element is required for schema validation and must be included
l Mandatory – The data element is not required for schema validation but IS required for FATCA reporting
l Optional – The data element is not required for FATCA reporting but may be provided if available
l Null – The data element is not used for FATCA reporting and may be left blank

Message Header
Information in the message header identifies the Financial Institution (FI) or Tax Administration that is sending the message.  It specifies when
the message was created, what calendar year the report is for, and the nature of the report (original, corrected, supplemental and so on)

This data element contains the bank (FFI)’s GIIN mapped from FATCA PARAMETER field, EIN. The GIIN is a 19-digit alphanumeric identifier
and should be entered with appropriate punctuation (period or decimal).  Example:  98Q96B.00000.LE.25.

This data element identifies the jurisdiction where the financial account is maintained or where the reported payment is made by the FI. This is
mapped from the LOCAL COUNTRY field of the COMPANY to which the ACCOUNT belongs to.

This data element identifies the jurisdiction of the tax administration that is the intended recipient of the message. If the STATUS in FATCA
PARAMETER is IGA1, then the receiving country will be the same as the Transmitting Country. Else it will be ‘US’.

This data element identifies the type of message. The only allowed value is ‘FATCA’.

This data element is a free text field assigning a unique identifying number for the message being sent. The ID will be
‘CUSTOMER.YYYYMMDD.n (sequence number – 1 for the initial message, 2 for the first correction and so on).

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 111 of 123
This data element is a free text field capturing the unique identifying number (as determined by the sender) that identifies a corrected message
being sent.  This data element MUST reference the original Message Reference ID created for the original message. When an earlier message is
being corrected, this element contains the Original Message Reference ID and MessageRefID contains the corrected message ID. For example, if
the unique reference for the original message is 100291.20141231.1’, then the ID of the corrected message is ‘100291.20141231.2’. The latter is
populated in the MessageRefID and the former in CorMessageRefID. If there is a further correction, the MessageRefID is ‘100291.20141231.3’
and the CorMessageRefID is ‘100291.20141231.1’.

This data element identifies the calendar year to which the message relates in YYYY-MM-DD format.  For example, if reporting information for
the accounts or payments is made in calendar year 2014, the field reads, “2014-12-31”.

This data element identifies the date and time when the message was compiled.  It is automatically generated when the XML message is being
generated. The format for use is YYYY-MM-DD’T’hh:mm:ss.  Fractions of seconds are not used.  Example:2015-03-15T09:45:30.

PersonParty_Type
The data elements in this section are used when the Account Holder is a natural person. This complex type comprises the following data ele-
ments:

TIN TYPE

This data element identifies the Tax Identification Number (TIN) used by the receiving tax administration to identify the Individual Account
Holder.  *If the message is being transmitted by an FI, this element must be present.It is mapped to TIN CODE field in FATCA TAX BASE.

This attribute identifies the jurisdiction that issued the TIN. It is mapped to the TIN COUNTRY field in FATCA TAX BASE.

ResCountryCode

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 112 of 123
The element defines the tax residence country code(s) for the individual being reported upon. It is mapped to the TAX RESIDENCE field in
FATCA TAX BASE.

NamePerson_Type

The field is updated from Customer.Name.1 from FATCA TAX BASE. In the unlikely event of the field in FATCA TAX BASE being blank, the
element is updated as NFN.

The field is updated from Customer.Name.2 from FATCA TAX BASE.

Address_Type

There are two options for Address type in the schema – AddressFix and AddressFree. AddressFix is the only option supported.

This data element is the country associated with the account holder’s address and updated from COUNTRY in FATCA TAX BASE.

These are updated based on Street, Address, Post Code, Town Country and Country Sub Entity fields in FATCA TAX BASE.

BirthInfo

This identifies the birth date of the individual and is updated only when TIN is not present.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 113 of 123
OrganisationParty_Type

This complex type identifies the name of an Account Holder or Payee that is an Entity as opposed to an Individual.

It comprises the following three data elements:

TIN_Type

This data element provides the tax identification number used by the receiving tax administration to identify the Entity Account Holder. If
GIIN is present in FATCA TAX BASE, the data element is updated with the GIIN. 

If the GIIN is not present, EIN from FATCA TAX BASE is updated. And if EIN is also not present, then TIN from FATCA TAX BASE is
updated.

This attribute identifies the jurisdiction that issued the TIN. It is mapped to the TIN COUNTRY field in FATCA TAX BASE if TIN is used
as the identifier, else it is left blank (i.e. with GIIN and EIN).

ResCountryCode

The element defines the tax residence country code(s) for the organisation being reported upon. It is mapped to the TAX RESIDENCE field
in FATCA TAX BASE.

Organisation Name

The name of the legal entity being reported. This is updated from Customer Name 1 in FATCA TAX BASE.

Reporting FI
This section identifies the financial institution that maintains the reported financial account or that makes the reported payment.

Reporting Group

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 114 of 123
This data element provides specific details about the FATCA report being sent by the reporting FI or tax administration transmitting the
message.

The following four data elements comprise the Reporting Group:  “Sponsor” and “Intermediary” are used only when necessary.  Each FATCA
report must contain either an “AccountReport” or a “PoolReport”. T24 generates either an Account Report or Pooled Report only. The
account report is generated for all the reportable statuses except the classifications for which pool report is required.

Account Report Type

AccountReport includes the following data elements.

DocSpec identifies the particular report within the FATCA message being transmitted.  It allows for identification of reports requiring
correction.  DocSpec_Type comprised the following elements:

This element specifies the type of report being submitted.  Allowable entries are:

1. OECD0 = Resend Data


2. OECD1 = New Data
3. OECD2 = Corrected Data
4. OECD3 = Deletion of Data
5. OECD10 = Resend Test Data
6. OECD11 = New Test Data
7. OECD12 = Corrected Test Data
8. OECD13 = Deletion of Test Data

Account Balance

This element provides the account number used by the financial institution to identify the account holder or payee.

For example: The account number may be the account number of a Custodial Account or Depository Account (Portfolio or Account ID).

This data element identifies an entity account holder or payee that is: (1) an owner documented FI with specified US owner(s); (2) a passive
NFFE with substantial or controlling US owner(s); (3) a nonparticipating FFI; or (4) a Specified US person.

These clients are identified from the Status type (OD_FFI, PASSIVE_NFFE, NON_PARTICIPATING and SPEC_US_PERSON statuses),
defined in FATCA REPORTING PARAMETER.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 115 of 123
If the Account Holder reported is an individual, the account holder's identifying information is reported here.

If the Account Holder reported is not an individual but an entity, the entity’s identifying information is reported here.

This data element identifies an entity account holder or payee that is: (1) an owner documented FI with specified US owner(s); (2) a passive
NFFE with substantial or controlling US owner(s); (3) a nonparticipating FFI; or (4) a Specified US person.

1. FATCA101 = Owner-Documented FI with specified US owner(s)


2. FATCA102 = Passive Non-Financial Entity with substantial US owner(s)
3. FATCA103 = Non-Participating FFI
4. FATCA104 = Specified US Person

Provide the name of any specified U.S. owners of an owner documented FI, substantial US owners or controlling U.S. persons of a passive
NFFE.

Provide the account balance or value of the reported financial account. This is updated from the base based on the currency settings in
FATCA REPORTING PARAMETER (USD or Account or Portfolio currency). This element is Numeric characters and three digit code for
currency type.

All payment amounts must be accompanied by the appropriate 3 digit currency code. The currency code is the currency in which the balance
above is reported.

All the with-holdable income (FDAP income from 2014, gross proceeds from 2017, etc.) is updated in the base from the respective effective
dates.

This element includes the payment made to the reported financial account during the reporting period. Payment information is a repeating
element, if more than one payment type needs to be reported.

For example, payment types may include the following: 

Depository accounts:

l The aggregate gross amount of interest paid or credited to the account during the calendar year.

Custodial accounts: 

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 116 of 123
l The aggregate gross amount of dividends paid or credited to the account during the calendar year
l The aggregate gross amount of interest paid or credited to the account during the calendar year
l The gross proceeds from the sale or redemption of property paid or credited to the account during the calendar year with respect to
which the FFI acted as a custodian, broker, nominee, or otherwise as an agent for the account holder; and
l The aggregate gross amount of all other income paid or credited to the account during the calendar year

Foreign reportable amounts: 

l The aggregate gross amount of foreign reportable amounts paid or credited to a Nonparticipating FFI may be reported as “FATCA
Other” payment.

Specific payment types listed are:

1. OECD503 = Dividends
2. OECD504 = Interest
3. FATCA518 = Gross Proceeds/Redemptions
4. FATCA519 = Other – FATCA.  (Example:  Foreign reportable amount)

Payment Amounts are entered with 2-digit fractional amounts of the currency in question. For example, one-thousand US dollars would be
entered as 1000.00

All payment amounts must be accompanied by the appropriate 3 digit currency code.

Pool report
A pool report is generated for all the statuses set for pool reporting in FATCA REPORTING PARAMETER.

This data element provides the number of accounts that are associated with the pool.  For example, input 25 if there are 25 accounts
described within the pooled report. This is from the count in FATCA POOL BALANCE for the status being reported.

This data element describes the type of status of the account holders or payees that are described within the pooled report.  The allowable
entries are:

1. FATCA201 = Recalcitrant account holders with US Indicia


2. FATCA202 = Recalcitrant account holders without US Indicia

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 117 of 123
3. FATCA203 = Dormant Accounts
4. FATCA204 = Non-participating foreign financial institutions

The relevant status is identified based on ID of FATCA POOL BALANCE record.

The balance is updated from FATCA POOL BALANCE. The aggregated balance reporting (foreign reportable amounts) for NPFFIs is handled
separately. 

The currency associated with the balance (USD).

The XML generation from FATCA TAX BASE is triggered using FATCA XML GENERATE.

It is used to generate new XML, resend, correct and delete based on the ACTION specified.

The XML REQUEST is used to generate both the account and pool reports.

The above extract is for a pool report. A similar request can also be placed for generating the account reports.

Based on the request, the system selects the relevant records from the tax base and generate XML as per the schema. The ID can be

1. AGGR (generates for all reportable clients)


2. AGGR-STATUS.TYPE (for example, AGGR-SPEC.US.PERSON) to generate only for clients identified as specified US persons
3. A- (Message reference). This is for generating a replacement message or void message.

The messages is generated by client type (specified US person, OD FFI, Passive NFFE). The number of accounts in a message can be restric-
ted by setting the maximum limit in FATCA REPORTING PARAMETER.

The system generates the XML as per the ‘IRS’ schema or UK HMRC schema based on FATCA REPORTING PARAMETER setting.

Form 8966 XML File Creation


l The FATCA.XML.REQUEST file generates the XML Schema for filing Form 8966.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 118 of 123
Field Name Description

YEAR Indicates the year for which the XML needs to be generated.

ACTION NEW, CORRECTION, VOID, AMEND are the values available. The default value is NEW, which means the message is
being generated for the first time.

REPORT.TYPE Updated based on ACTION selected

l FATCA1 = New Data


l FATCA2 = Corrected Data
l FATCA3 = Void Data
l FATCA4 = Amended Data

NARRATIVE Displays the comment for the ACTION selected.

l Authorise the FATCA.XML.REQUEST, to update the work file based on the request in FATCA.TAX.BASE record.
l Run the FATCA.BASE.XML.GENEREATION service, this selects the work file based on that FATCA.TAX.BASE @ID and gen-
erates the XML message in the specified output mentioned in FATCA.REPORTING.PARAMETER from where message can be
routed to external systems.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 119 of 123
l Copy the generated XML file in the local from the output and can be viewed as shown below.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 120 of 123
Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 121 of 123
APPENDIX 1 - Fatca Key Dates

The Fatca Key Dates are provided in the following table:

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, pass through payments and reporting requirements (official publication in Internal Rev-
enue 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 are automatically exten-
2012 ded 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.

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 122 of 123
Year Date Description

2015 March 15, 2015 Reporting on with holdable 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.)

Foreign Account Tax Compliance Act - User Guide - Release R15.000 - Page 123 of 123

You might also like