In the ‘Regulatory details’ step within the Enrich stage, the user (who, depending on the financial institution’s Target Operating Model, can be for example 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 FATCA 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 FATCA status, thus gaining operational efficiency.
For customers being an individual, the user can indicate if the customer is a US citizen and, if yes, enter the Tax Identification Number (TIN).
For customers being an entity, the user can indicate the relevant FATCA classification amongst the following four values: “Active NFFE”, “Reporting Model 1 FFI”, “Reporting Model 2 FFI”, “None of the above”. Naturally, this section is configurable by the financial institution according to their procedure and local law, which may allow for other FATCA classifications to be selected without collecting first the self-certification form.
In its out-of-the-box behaviour, the information in this initial FATCA assessment does not pre-populate the relevant items of the FATCA questionnaire in Due Diligence stage, but that can be easily configured.