Common Reporting Standard (CRS) – Advisory Services

Common Reporting Standard implementation step by step

Step 1 - Training & Awareness :

• Train existing FATCA taskforce on Common Reporting Standard specific requirements, focusing on delta between FATCA / EUSD and CRS

Step 2 - Strategy :

• Review strategic choices made for FATCA/EUSD in the light of Common Reporting Standard; considering governance, process, system and data dimensions
• Consider impact on business model
• Consider link with local reporting regimes
• Assess opportunities for Business Process Outsourcing

Step 3 – Communication (internal & to clients) :

• What is the impact of potential Business Model change?
• What is to be communicated? To whom?
• How to consider data privacy per jurisdiction?

Step 4 – Classification & Remediation :

• Identify new classification/remediation criteria and workflow applicable to CRS
• Define both classification input data and classification operations in order to highlight reusability (what is to be reused / updated / removed from FATCA factory in the context of CRS)

Step 5 – Products assessment :

• Identify cases of differing CRS classification of products (e.g. banking, funds, life insurance, etc.) compared to FATCA, taking into account specifics per jurisdiction

Step 6 – Data & IT :

• Identify data fields, aggregation / classification / reporting mechanics under CRS that are different from FATCA to prepare foundations for the data enrichment / extension / tailoring phase

Step 7 – Legal & Procedures :

• Identify legal documentation (such as general terms of business, fund prospectuses, insurance contracts) to be reviewed in order to extend FATCA wording with CRS wording
• Identify changes / extensions to be made to FATCA operational procedures to cover relevant CRS operational procedural aspects

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