Triggers
Out-of-the-box, CLM triggers the displaying of the FATCA questionnaire in every customer onboarding, regardless of the products requested by the customer. The majority of financial institutions, in fact, prefers to have in the customer file, already at onboarding, the relevant tax classification in case the customer falls afterwards under the relevant FATCA reporting obligations.
However, CLM can support the other approach in the market where the relevant FATCA questionnaire is displayed only as per strictly dictated by the regulation, i.e. when the product requested by the customer falls within the definition of “financial account.”
In both approaches, the financial institution that must perform the tax classification of the customer is the one located in the country where the product is booked, if that country has signed an IGA. However, if the financial institution of the product booking location is a branch in a non-IGA country, but their Head office instead is, then that branch must also be FATCA compliant. The same applies if the financial institution is a Participating FFI.
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