This document summarizes a presentation on scaling FATCA data collection and reporting. The presentation featured several speakers from banks and technology companies discussing FATCA challenges and best practices. Key points included the need to integrate FATCA identification within existing customer due diligence processes, address data quality issues, and leverage existing CDD investments and processes to streamline FATCA compliance. The presentation covered FATCA account review requirements and suggested looking for flexibility, data management best practices, and tools to help with issues detection, investigations, documentation, and leveraging CDD for FATCA alignment.

1. Scaling FATCA’s Data
Mountain
Technologies and best practices to
streamline data collection, reporting
and monitoring
Thursday, February 6, 2014 | 10:30 – 11:30 AM
Speakers:
Kelvin Dickenson, Ron King, Allen Love, Ed Sander

2. Ron King
Chief AML Officer
Scotiabank
Toronto

3. Allen Love
SVP, BSA Officer and Deputy Global AML Officer
TD Bank
Philadelphia

4. Kelvin Dickenson
Global Risk Management Solutions
D&B
New York

5. Ed Sander
Global VP and General Manager, AML Solutions
NICE Actimize
New York

6. What We’re Seeing In the Market
• Focus is split on KYC and tax withholding
– USFIs forced to act as tax withholding agents
– FFIs revisiting customer due diligence programs
• Data availability & quality are huge concerns
• Injecting FATCA ID w/in existing CDD processes
• Regulation uncertainties still continue
– IGA network continues to evolve

7. Areas Impacted by FATCA Regulation

8. FATCA Account Identification is Complex

9. Business Challenges to Think About
• Avoiding regulatory and reputational impacts
– Legal & financial penalties plus reputational risk
• Complex regulation  significant business change
– Overhauls ID of customers & beneficial ownership
• FATCA compliance > huge operational & IT impact
• Data quality as lever to better customer insight
– New paradigm for managing customer information
• Reality of future “FATCA-like” regulation

10. FATCA Requires Comprehensive Review
• Review required for individual
and entity customers:

11. What To Look For in a FATCA Solution

12. Data Management: Best Practices
• Data capture: “Simplify”
– Form-based with dynamic Q&A capability
– Integration with on-boarding systems
• Data consolidation: “Complete 360 View”
– Identity verification details & related account info.
– Aggregate customer balance over multiple accounts
• Data enrichment: “Validate & Verify”
– Auto-population of missing data; 3rd Party callouts

13. Issues Detection: Best Practices
• Data cleansing and enrichment: “Identify”
– Customer identity discrepancies
– US address validation
• IRS indicia detection: “Manage Change”
– US account identification (pre-existing / new)
– US ownership identification (pre-existing / new)
• Tracking and review: “Monitor”
– Recalcitrant account status; Customer status changes
– Documentary tracking

14. Investigations: Best Practices
• Automated and manual workflows
– Letter creation/document request and response
– IRS request management
• FATCA customer account classification
– Identification of passive NFFEs* and beneficial
ownerships
• Complete customer record
– Customer/entity profile info.; indicia alert details
– Shows related accounts/entities and ownership
*Non-Financial Foreign Entities

15. Documentation Management: Best Practices
• Document capture: “Single-Point-of-Access”
– Associate documents with customer record
– Centralize documentary account / reference info.
– Ability to Integrate w/document management systems
• Document tracking: “Flag Changes”
– Manage & track document expiration (passport, etc.)
• Email integration: “Prepare for Audits”
– Integrate emails/attachments as part of workflow
– Ability to audit email exchanges

16. Leverage CDD Investments for FATCA
Customer Due Diligence
– A Cornerstone of Your
AML Program
FATCA
Alignment with CDD
 Knowing / understanding a customer
 Collection of customer information
 Defining the acceptable business
context
 Customer classification
 Understanding ongoing customer
relationship
 Tracking of documentation and
evidentiary information
 Periodic reporting to regulators
 Ongoing review and verification of
customers

17. FATCA & CDD Common Capabilities
FATCA
CDD
Customer
Verification
Data
Collection
Customer
Risk Ranking
Document
Request & Response
Customer
Classification
Anticipatory Behaviour
Capture
Indicia
Detection
Models
Documentary Tracking
Customer Risk
Detection
Models
FATCA
Workflows
Ongoing Review
Periodic Reporting
Due Diligence
Workflows

18. Data Considerations for IGA/non-IGA
• Flexibility in your technology solution
– You’ll need to run different modules & business rules
– Different IGA agreements will require different
FATCA-related business logic and data elements
• Real-time services that are FATCA specific
– Data verification across jurisdictions
– US IRS indicia checks that are automated
– FATCA determination status that is ongoing

19. 
Final Thoughts –

FATCA
CDD Benefits
• Streamline existing processes for Account ID
– Consolidate and enrich data across multiple sources
• Increase productivity and operational efficiency
– Simplify applicant and ongoing client review
– Automate document capture and reporting process
– FATCA requires flexibility and extensibility in CDD
• Leverage to improve customer-centric approach
– Centralized, comprehensive “single-customer-view”

20. Your
Questions