Remediation

FATCA One™ implements a concept of Rule Bases. A Rule Base is based on reporting regulations to a specific jurisdiction, reporting jursidiction, and fiscal year. The Rule Base incorporates rules based on:

• Specific differences based on the Inter-Governmental Agreements (IGA) or local law implementations thereof
• The rules and XML generation determined by the type of agreement: US FATCA, UK FATCA, or Common Reporting Systems (CRS)
• The phasing in of rules over time
• The evolving and shifting regulatory environment

Download the FATCA One™ Data Sheet The following are examples of types of Rule Bases:

• Cayman Islands reporting to the US for Fiscal Year 2014
• Cayman Islands reporting to the UK for Fiscal Year 2014
• Bermuda reporting to the US for Fiscal Year 2016
• US reciprocal reporting by US institutions to Canada for Fiscal Year 2015

As data is loaded or modified, FATCA One™ applies the Rule Base to raise Red and Yellow Flags to identify issues that require review and Green Flags to show those records that are complete and either need to be reported or don't need to be reported. Red flags identify major deficiencies including findings of indicia or missing required data such as an address. Yellow flags are issued for minor deficiencies such as high value accounts requiring relationship manager review or missing non-required data such as a TIN, which will be required in the future.

When a compliance analyst researches and issue, they must sign-off on the collection of curative documentation, optionally upload related scanned documentation, and record an explanation before clearing a flag excusing that record from being reported. FATCA One™ allows for the reporting of dormant or recalitrant accounts. This data collection tracks which records should be reported or not reported, allows for an audit trail for auditors or regulators, and promotes accountability within the organization.