Responsible Officer certifications under QI and FATCA
Are you ready to sign the Responsible Officer certifications under QI and FATCA?
The US Qualified Intermediary (QI) and Foreign Account Tax Compliance Act (FATCA) are now considered business as usual. In 2018, the designated Responsible Officer (RO) will be required to certify the compliance of his or her organisation with these regimes. Although the deadlines for certification seem distant, the RO should take a step back now to consider the needs of his or her institution and how best to position it for the upcoming certifications. Further, financial institutions will be required to demonstrate the adequacy of the internal reporting/interaction between the executing functions and the senior management to enable informed compliance certifications.
Deloitte has developed the following offerings to support the RO on his or her path to certifying compliance:
RO refresher trainings
Deloitte’s 2-hour RO refresher trainings reinforce the relevant key elements of QI and FATCA and keep the RO informed on recent developments, best practices and regulatory updates.
Compliance program support manual
Deloitte’s compliance program support manual assists in the control assessment process following a simple and step-by-step approach to allow non-experts to understand whether QI and FATCA processes are aligned with the requirements of those regimes.
In addition, this manual, with limited tailoring, can also be used as an operational directive or as an addendum to such a directive.
Framework compliance program
Deloitte’s framework compliance program provides detailed information about implementing effective internal controls within a financial institution, the RO’s role, responsibilities and liabilities, as well as assessing and measuring key risks arising from the most critical QI and FATCA requirements. Deloitte’s framework compliance program also includes an extensive matrix of example internal controls aligned to the requirements of the compliance programs.
Deloitte’s certification checklist assists the RO in keeping track of the work that has taken place within the organisation for the relevant period and following a structured list of action items enables him or her to identify key steps prior to the compliance certification.
Certification governance and responsibility matrix
Deloitte will use its established methodology to assess the existing governance and responsibility matrix of the financial institution against QI and FATCA requirements to ensure it is sufficiently robust.
In addition, Deloitte can support the QI or PFFI in developing its own matrix.
QI/FATCA review or health-check
Through to use of its established methodology, Deloitte can participate in or perform the formal periodic review. Alternatively, Deloitte can perform a health-check in order to capture any deficiency prior to the formal review. This preventative measure will expose failures and weaknesses, allowing corrective actions to be implemented and thus mitigating the need to report such failures in the context of the periodic review.
Deloitte’s tailored management reporting solution identifies reported client populations, shifts and trends. The solution can facilitate the monitoring of periodic internal compliance certifications and form the basis for data quality improvement.