FATCA is the acronym for Foreign Account Tax Compliance Act enacted by the US Government as part of the Hiring Incentives to Restore Employment (HIRE) Act, in 2010.The purpose of FATCA is to help Internal Revenue Service (IRS) to identify and collect tax from US Persons (USP) holding financial assets outside US.
This chapter deals with Foreign Account Tax Compliance regulation. It includes the description about functions that would help Oracle FLEXCUBE to support FATCA.
This chapter contains the following sections:
You can maintain products, account class and instruments that is applicable for FATCA withholding. The system will mark all the contracts, accounts and deals created using any of the listed values in the maintenance as US sourced obligation. The maintenance will also indicate whether the obligation created should be considered at the time of computing FATCA balance for the customer and whether grandfathering is applicable for the obligation.
You can store a list of products, account classes or instruments at a bank level using ‘FATCA - Product, Account Classes and Instruments’ screen, invoked from the Application Browser. You can invoke this screen by typing ‘STDFATPR’ in the field at the top right corner of the Application tool bar and clicking the adjoining arrow button.
You can specify the following details:
Module Code
Specify the module code for the product or account class. You can also select the valid module code from the adjoining option list.
Product Code
Specify the product, account class or instrument code. You can also select the valid product code from the adjoining option list.
Product Description
The system displays the description for the selected product code.
Type
Select the type of the product from the drop-down list. Following are the options available in the drop-down list:
Incl. Bal.
Check this box if the balance of the contract account should be included for FATCA.
Allow Grandfathering
Check this box if the grandfathering of contracts booked using the product/account class/instrument is allowed.
Grandfathered obligations needs to be checked based on the ‘Allow Grandfathering’ field at the ‘FATCA - Product, Account Classes and Instruments’ screen. The obligation is grandfathered if Account Opening Date is less than Grandfathered cutoff date and there are no changes in tenor, amount or rate of interest after grandfathered cutoff date.
While authorizing, if customer is a reportable FATCA status or is recalcitrant, the system will identify all accounts, contracts and deals for the customer booked using products, account classes or instruments. For each of the customer the total FATCA balance should be updated in the threshold currency maintained for that type of customer. The FATCA balance of the customer will be the sum total of all balances of the customer obligations.
If the maintenance is being modified, then at the time of authorization of the maintenance, the system will perform the following:
If a new product, account class or instrument is being added to the list, then at the time of authorization of the maintenance, the system should scan for all contracts, accounts or deals booked using the newly added product, account class or instrument with ‘Incl. Bal.’ field checked. If the counterparty of such a contract, account or deal has a reportable FATCA status, a row should be inserted into the FATCA tracking table.
This section contains the following topics:
You can maintain the FATCA parameters for different customer types in ‘Customer Type-wise FATCA Parameters’ screen. To invoke this screen type ‘STDFATCA’ in the field at the top right corner of the Application tool bar and click on the adjoining arrow button.
You can capture the following in this screen:
Customer Type
Select the type for customer from the adjoining drop-down list. The options available are:
Threshold Currency
Select the threshold currency from the adjoining option list.
Threshold Amount
Specify the threshold amount.
Escrow Days
Specify the number of days for which a transaction for the type of customer can he held in Escrow account.
Escrow Warning Before Days
Specify the number of days before the expiry of Escrow period, when an alert should be raised.
FATCA Classification
Specify the FATCA classification for the given customer type.
Numeric Eqv.
Specify a numeric equivalent for FATCA classification. The numeric value should be unique for the given customer type and you cannot repeat a numeric for the given customer type.
Reportable
Check this box to indicate that the FATCA Classification mentioned is Reportable to IRS.
US Withholding Agent
Check this box to indicate if the status defined is a US withholding agent or not.
The check box for US withholding agent must be enabled only if the customer type is Bank. This check box should be unchecked for all other customer types. If the customer is a bank type of customer, then this check box should be enabled. A single status should be mandatorily defined as US withholding agent.
Category
Select the category of documents from the adjoining option list.
Type
Specify the type of document.
Verification Limit in Days
Specify the number of days allowed to submit the documents for FATCA verification.
Note
If the check box ‘FATCA Applicable’ in the ‘Bank Parameters’ screen is not checked, then saving a record in Customer Type Wise FATCA parameters is not allowed.
You can view the customer type details maintained in the ‘Customer Type-wise FATCA Parameters’ screen using the ‘Customer Type-Wise FATCA Parameters Summary’ screen. You can invoke this screen by typing ‘STSFATCA’ in the field at the top right corner of the Application tool bar and clicking on the adjoining arrow button.
In the above screen, you can base your queries on any or all of the following parameters and fetch records:
Select any or all of the above parameters for a query and click ‘Search’ button. The records meeting the selected criteria are displayed.
If you are allowed to query customer information, then system displays the following details pertaining to the fetched records:
This section contains the following topics:
You can maintain the FATCA classification details of a customer in the ‘Entity FATCA Classification’ screen if the US Indicia conditions are satisfied or changed. To invoke this screen type ‘STDCFCLF’ in the field at the top right corner of the Application tool bar and click /on the adjoining arrow button..
Entity ID
Select the entity ID from the adjoining option list.
Entity Name
The system displays the full name of the entity.
Entity Location
This indicates the origination of the classification record.
Entity Type
Based on the entity ID selected, the system displays the entity type.
Local Branch Code
The system displays the local branch code.
US Indicia Present
The check box US Indicia Present is checked based on the FATCA classification batch or the authorization of a customer record. However you can check or uncheck the box after performing due diligence.
If this box is checked and the ‘FATCA Classification’ status is ‘PENDING CLASSIFICATION’, then
If the customer has US indicia, the batch will extract the customer account and obligations based on FATCA product, account class and instruments maintenance. The batch will add up the balances based on ‘Inc Bal.’ field of the FATCA product, account class and instrument maintenance.
The FATCA classification batch will check address fields in all the CASA accounts for the customer and in the message address fields maintained for the customer along with the customer information (CIF) record for US indicia details. If US indicia is found either in the customer information (CIF) data or in any of the customer account data or in the customer message address, the ‘US Indicia’ field at the customer FATCA classification level will be selected the bank will do further due diligence.
Recalcitrant
The check box Recalcitrant is checked based on the FATCA classification batch or the authorization of a customer record.
You can check this box if:
FATCA Classification
The system displays the value maintained for the field ‘FATCA Classification’ at ‘Customer Type Wise FATCA Parameters’ maintenance screen. However, you can modify by selecting the FATCA Classification from the adjoining option list. The system displays the value for this as ‘PENDING CLASSIFICATION’ initially (during the Batch run/ Customer Authorization).
Remarks
Specify remarks, if any.
Tax identification Number (TIN)
Specify the tax identification number of the customer.
TIN Expiry Date
Specify the expiry date of the tax identification number. If TIN Expiry Date is blank, it indicates that the tax identification number does not expire.
Balance Currency
The system displays the total balance of the customer.
FATCA Balance
Specify the total balance of all accounts/contracts for the customer, that are included for FATCA reporting set.
If the customer’s FATCA balance is greater than or equal to the threshold amount maintained for the customer type, and:
If the customer’s FATCA balance is less than the threshold amount maintained for customer type then:
Responsible Officer Name
Specify the name of the officer responsible for FATCA compliance.
Responsible Officer Designation
Specify the designation of officer responsible for FATCA compliance.
Responsible Officer Address Line 1
Specify the address of the officer responsible for FATCA compliance.
Responsible Officer Address Line 2
Specify the address of the officer responsible for FATCA compliance.
Responsible Officer Address Line 3
Specify the address of the officer responsible for FATCA compliance.
Responsible Officer Address Line 4
Specify the address of the officer responsible for FATCA compliance.
Responsible Officer Telephone
Specify the telephone number of the officer responsible for FATCA compliance.
Responsible Officer Email ID
Specify the e-mail ID of the officer responsible for FATCA compliance.
GIIN Verified
Check this box to indicate whether the GIIN number has been validated against the list of GIIN received from IRS.
Withhold for this Financial Institution
Check this box to to indicate that the customer requires withholding on their behalf. The bank will withhold the FATCA classification for that particular financial year.
This field is applicable only if the bank is a USWA and the customer is a bank type of customer.
Employer Identification No. (EIN)
Specify the employer identification number.
EIN Issue Date
Specify the date when the employer identification number is issued.
EIN Expiry Date
Specify the date when the employer identification number has to be revalidated or renewed. If EIN Expiry Date is blank, it indicates that EIN does not expire.
Global Intermediary Identification Number (GIIN)
Specify the Global Intermediary Identification Number issued to the bank by IRS.
GIIN Issue Date
Specify the date on which GIIN was issued.
GIIN Expiry Date
Specify the date on which GIIN will be expiring.
Tracking Required
Check this box to indicate that the customer should be tracked for FATCA classification or re-classification.
If this box is unchecked, then it is mandatory to maintain ‘Tracking Closed Date’.
Tracking Closed Date
Specify the tracking closed date. Tracking closed date cannot be a future date.
IGA Status
Select the Inter-Governmental Agreement type from the drop-down list. The list displays the following values:
Note
This field is enabled only if the entity type is Bank (B).
The system records any change to customer classification whether automatically or manually here.
Date Logged
The system displays the application date.
Reason for Logging
The system displays the details about the user making the changes.
Logging Remarks
Specify logging remarks, if any.
US Indicia Updated
The system displays if the ‘US Indicia’ is updated by the system or not.
Recalcitrant Updated
The system displays if the ‘Recalcitrant’ is updated by the system or not.
Source Code
The system displays the source code.
Click ‘Entity Account and Balances’ tab to specify the entity account and balances details.
Obligation ID
Specify the obligation ID.
Obligation Type
Select the type of obligation from the drop-down list. Following are the options available in the drop-down list:
Prd/AcCls/Security
Specify the security details.
Source
Specify the source details.
Type
Select the type from the drop-down list. Following are the options available in the drop-down list:
Issue Date
Specify the issue date.
Expiry Date
Specify the expiry date.
CCY
Select the currency from the option list.
Balance
Specify the balance.
US Sourced
Check this box to enable US sourced.
Include Bal
Check this box to include the balance.
Grandfathered
Check this box to enable grandfathered.
Last Updated Date
The system displays the last updated date.
Remarks
Specify remarks, if any.
Maker ID
The system displays the maker ID.
Click ‘Withholding Audit Log View’ button to view the FATCA withholding log in the ‘FATCA Withholding Audit Log View’ screen. You can view the withholding log as a drill down from the FATCA obligation record and also independently. The withholding log provides a means to track FATCA withholding.
For more information on viewing FATCA Withholding Audit Log, refer to the section ‘Viewing FATCA Withholding Log’ in this User Manual.
Click ‘Fields’ to capture additional FATCA details.
You can view the FATCA Classification details of the customers maintained in the ‘Customer FATCA Classification’ screen using the ‘Customer FATCA Classification Summary’ screen. You can invoke this screen by typing ‘STSCFCLF’ in the field at the top right corner of the Application tool bar and clicking on the adjoining arrow button.
In the above screen, you can base your queries on any or all of the following parameters and fetch records:
Select any or all of the above parameters for a query and click ‘Search’ button. The records meeting the selected criteria are displayed.
If you are allowed to query customer information, then system displays the following details pertaining to the fetched records:
The system evaluates the US Indicia of the customer based on the following criteria maintained in ‘Customer Maintenance’ screen. The system will apply the criteria on creating a new customer record / on Modification of new customer record:
Note
US Territories Included for FATCA assessment are:
All residents born in the above listed US commonwealth territories are automatically granted US citizenship and hence qualify for FATCA evaluation. The ISD Codes of these territories are also +1 as that of US
You can track the customers whose FATCA classification or re-classification is pending or needs due diligence. You can monitor such records using the ‘Customer FATCA Tracking’ query screen. To invoke this screen type ‘STSFCTRK’ in the field at the top right corner of the Application tool bar and click on the adjoining arrow button.
In the above screen, you can base your queries on any or all of the following parameters and fetch records:
Select any or all of the above parameters for a query and click ‘Search’ button. The records meeting the selected criteria are displayed.
If you are allowed to query customer information, then system displays the following details pertaining to the fetched records:
You can view FATCA withholding log. You can view the withholding log as a drill down from the FATCA obligation record and also independently in the ‘FATCA Withholding Audit Log View’ screen. The withholding log provides a means to track FATCA withholding.
You can invoke the ‘FATCA Withholding Audit Log View’ screen by typing ‘TADFWHLG’ in the field at the top right corner of the Application tool bar and clicking the adjoining arrow button.
You can view the FATCA Withholding Audit Log based on the following parameter:
Entity ID
Specify a unique identification ID for the entity. Alternatively, you can select the entity ID from the option list. The list displays all the entity ID maintained in the system.
Click ‘Execute Query’ button, the system displays the following details pertaining to the FATCA Withholding Audit Log based on the entity ID selected.
This section contains the following topics:
You can process referred transactions manually in the ‘Referral Processing’ screen. You can fetch a FATCA referral record, which is in E – ESCROW and P – PENDING status to decide whether to perform withholding or not.
While saving the FATCA referral record, the referral status gets updated to the status ‘C’ – CLOSED and the authorization status of the referral record gets updated to ‘U’ – Unauthorized.
You can perform the following actions in the ‘Referral Processing’ screen:
You can invoke the ‘Referral Processing’ screen by typing ‘TADFATRF’ in the field at the top right corner of the Application tool bar and clicking the adjoining arrow button.
You can specify the following details:
Referral Number
Specify the referral number of the FATCA referral record.
The system displays the following details:
To process referred transaction manually, click ‘Execute Query’ button. You can specify the following details:
Decision
Select the decision from the drop-down list. The list displays the following values:
Transfer Module
Select the module for transferring the amount from the drop-down list. The list displays the following values:
Transfer Product
Specify the product for transferring funds from Escrow account to either tax account or beneficiary. Alternatively, you can select the transfer product from the option list. The list displays all product codes belonging to the selected 'Transfer Module'.
Justification
Specify the justification for the decision taken.
Click the ‘Save’ button to save the transaction. The system saves the record and updates the status to ‘C-Closed’.
You can view the summary of referral processing in the ‘Referral Processing Summary’ screen. It displays the status of the records maintained, whether it is authorized, unauthorized or rejected.
You can invoke this screen by typing ‘TASFATRF’ in the field at the top right corner of the Application tool bar and clicking on the adjoining arrow button.
In the above screen, you can base your queries on any or all of the following parameters and fetch records:
Click ‘Search’ button. The system identifies all records satisfying the specified criteria and displays the following details for each one of them:
This section contains the following topics:
You can maintain FATCA withholding rules in the ‘FATCA Rule Maintenance’ screen. In this screen, you can describe a set of conditions and return the resultant decision. The FATCA Withholding Rule Maintenance helps to create a rule that determines whether FATCA withholding is required or not. While defining tax rule, a flag indicates whether the tax rule is a FATCA based rule or not. If case the tax rule is a FATCA based rule, then a FATCA withholding rule has to be linked to the tax rule.
During evaluation of the tax rule, the FATCA withholding rule is evaluated first and based on the outcome of the FATCA withholding rule, the tax rule computes the withholding tax.
The conditions you can describe are as follows:
The resultant decision are as follows:
The tax computation for the resultant decision are as follows:
You can invoke the ‘FATCA Rule Maintenance’ screen by typing ‘TADFATTX’ in the field at the top right corner of the Application tool bar and clicking the adjoining arrow button.
You can specify the following details:
Withholding Rule Code
Specify a unique rule ID for the FATCA rule
Withholding Rule Description
Specify the description of the FATCA Rule.
Default
Select the default option from the drop-down list. The list displays the following values:
All the SDEs that are allowed for the rule are provided in this tab. You can select one or more than one SDEs to be used in the rule. Each system data element appears only once in the list. To specify SDE, click ‘System Data Elements’ tab.
System Data Elements
Specify the SDEs allowed for user in expression.
You can use the following SDE’s as part of the formula FATCA Tax rule Maintenance:
There would be no change in the way IC or FATCA tax rules are maintained
For more information on SDEs, refer to the section ‘System Data Elements Maintenance’ in the chapter ‘Maintaining System Data Elements’ in Interest and Charges User Manual.
You can build the expression by picking up elements and associated operators in the expression. To build expression, click ‘Expression Builder’ tab.
Expression Number
Specify the expression number.
Condition
Specify the condition of the expression.
Return Value
Select the return value from the drop down list. The list displays the following values:
System Data Element
Select the SDEs to help build the expression for operator. The list displays the following values:
Operators
Select the operators from the drop-down list. The list displays the following values:
You can view the summary of FATCA Rule in the ‘FATCA Rule Summary’ screen. It displays the status of the records maintained, whether it is authorized, unauthorized or rejected.
You can invoke this screen by typing ‘TASFATTX’ in the field at the top right corner of the Application tool bar and clicking on the adjoining arrow button.
In the above screen, you can base your queries on any or all of the following parameters and fetch records:
Click ‘Search’ button. The system identifies all records satisfying the specified criteria and displays the following details for each one of them:
Income codes are codes used by FATCA reports for withheld transactions. You can define these income codes for an amount tag and transaction code combination in the ‘Reporting Income Code Maintenance’ screen.
Note
For a given income code, the combination of transaction code and amount tag will be unique.
You can invoke this screen by typing ‘TADINCCD’ in the field at the top right corner of the Application tool bar and clicking on the adjoining arrow button.
In this screen, you can define multiple transaction code and amount tag combinations for an income code.
Income Code
Specify a unique identifier for income.
Income Code Description
Specify the description of the income code.
Module ID
Specify the module ID for the amount tag to be picked up. Alternatively, you can select the module ID from the option list. The list displays the module IDs maintained in the system.
Amount Tag
Specify the amount tag that would part define the income code. Alternatively, you can select the amount tag from the option list. The list displays the amount tags maintained in the system.
Transaction Code
Specify the transaction code. Alternatively, you can select the transaction code from the option list. The list displays the transaction codes maintained in the system.
You can view the summary of reporting income code summary in the ‘Reporting Income Code Summary’ screen. It displays the status of the records maintained, whether it is authorized, unauthorized or rejected.
You can invoke this screen by typing ‘TASINCCD’ in the field at the top right corner of the Application tool bar and clicking on the adjoining arrow button.
In the above screen, you can base your queries on any or all of the following parameters and fetch records:
Click ‘Search’ button. The system identifies all records satisfying the specified criteria and displays the following details for each one of them:
This section contains the following topics:
You can define the following intraday batches to identify the customers based on FATCA classification:
FATCACOM batch scans all the customer records to check whether the customers qualify for FATCA. The batch identifies the FATCA classified customer records and marks them in FATCA classification data stores.
Note
The FATCACOM batch should be run at least once so that the existing customer records can be scanned to check if they are eligible for FATCA.
The processing logic of the batch is available under the section ‘FATCA Classification Data Population into Data Stores’.
In order to enable this batch, you need to maintain the following details in ‘Batch EOD Function Input’ screen.
Function ID
Specify the function ID as FATCACOM.
End of Cycle Group
Select the end of cycle group ‘Transaction Input’.
Report Orientation
Select ‘Not Applicable’.
For further details regarding ‘Batch EOD Function Input’ screen, refer to the chapter ‘Automated End of Cycle Operations’ in the Automated End of Day user manual.
FATCAEXT batch extracts data for FATCA reporting. The data for FATCA reporting is extracted usually at the end of a financial year. However, at the bank’s discretion, the report can be extracted on any date. An ad-hoc (intra-day) batch facilitates extraction of data for FATCA reporting.
The parameters and details of FATCAEXT batch are as follows:
The processing logic of the batch is available under the section ‘FATCA Classification Data Population into Data Stores’.
In order to enable this batch, you need to maintain the following details in ‘Batch EOD Function Input’ screen.
Function ID
Specify the function ID as FATCAEXT.
End of Cycle Group
Select the end of cycle group ‘Transaction Input’.
Report Orientation
Select ‘Not Applicable’.
For further details regarding ‘Batch EOD Function Input’ screen, refer to the chapter ‘Automated End of Cycle Operations’ in the Automated End of Day user manual.
This section contains the following topics:
FATCAINC batch checks whether a change in the customer records affects the existing FATCA classification of a customer. This batch identifies such customer records and marks them in FATCA classification Data-stores.
The data in the FATCA data store is picked up by the FATCAINC batch to determine any change in their US Indicia or recalcitrant status based on the following conditions:
The processing logic of the batch is available under the section ‘FATCA Classification Data Population into Data Stores’.
In order to enable this batch, you need to maintain the following details in ‘Batch EOD Function Input’ screen.
Function ID
Specify the function ID as FATCAINC.
End of Cycle Group
Select the end of cycle group ‘Transaction Input’.
Report Orientation
Select ‘Not Applicable’.
For further details regarding ‘Batch EOD Function Input’ screen, refer to the chapter ‘Automated End of Cycle Operations’ in the Automated End of Day user manual.
This section contains the following topics:
The system populates the data related to FATCA classification into the FATCA classification data stores as per the logic provided below.
This logic is applicable only if ‘FATCA Applicable’ flag is set to ‘Y’ in the ‘Bank Parameters Maintenance’ screen.
Case 1: The customer is an Individual or Corporate customer and satisfies US indicia
conditions, then the process is as follows:
If a customer record is marked by the system as ‘Recalcitrant’ with Recalcitrant flag set as ‘Y’, the system will not reset it to back to ‘N’, even if the conditions no longer applies on that customer at a later stage. You need to manually deal with such situations by applying due-diligence. You can set the ‘Recalcitrant’ flag manually as deemed fit.
Case 2: If the customer is an Individual or Corporate and does not satisfy US indicia
conditions, then the process is as follows:
Case 3: The customer is a Bank.
Note
You can maintain the default classification - 'PENDING CLASSIFICATION' for each type of the customers if they wish to register for FATCA classification.
Oracle FLEXCUBE facilitates linkage of required documents automatically during due diligence. When a customer is classified for ‘PENDING CLASSIFICATION’ in the Maintaining Customer Type-wise FATCA Parameters (STDFATCA) screen, the system automatically populates the check list for FATCA due diligence.
The system populates the check list automatically for a customer in the following scenarios:
SCENARIO |
Obligation Data Populated
|
Grandfather Check
|
FATCA
|
FATCA Classification
|
US Indicia
|
Recalcitrant
|
BATCH : FATCA COMPLETE
|
Yes -- if Static US Indicia is Y |
Yes |
Yes |
1. If FATCA Balance >=Threshold
Amount |
Yes - Based on Static Criterions only |
Defaulted 'N' |
BATCH : FATCA INCREMENTAL
|
No |
Yes |
No |
No |
No |
Yes |
CUSTOMER CREATION (From STDCIF)
|
No |
No |
No |
If Static US Indicia is Y, then PENDING CLASSIFICATION |
Yes-Based on Static Criterions |
Defaulted to 'N' |