In the ‘Regulatory details’ step within the Enrich stage, the user (who, depending on the financial institution’s Target Operating Model, can be the back-office department responsible for performing due diligence on the customer, or the Relationship Manager, or a Mid-office employee) has the option to perform an initial CRS assessment of the customer based on information already in possession of the financial institution – for example, because collected during onboarding – and/or publicly available information. Not having to obtain from the customer and process the appropriate self-certification form, duly filled and signed, will result in shortening the time needed to determine the CRS status, thus gaining operational efficiency.
For customers being an individual, the user can indicate if the customer is tax resident in a reportable jurisdiction and, if yes, enter the data about the relevant tax residence country and Tax Identification Number (TIN) or equivalent number.
For customers being an entity, the user can indicate the relevant CRS classification. Naturally, this section is configurable by the financial institution according to their procedure and local law, which may allow for all CRS classifications or only a subset of them (for example, those making the customer non reportable) to be selected without collecting first the self-certification form.
In its out-of-the-box behaviour, the information in this initial CRS assessment does not pre-populate the relevant items of the CRS questionnaire in Due Diligence stage, but that can be easily configured.