fatca software evaluative case studies

The Foreign Account Tax Compliance Act (FATCA)

Evaluative Case Studies on FATCA Implementation and Compliance SoftwareSESSION 8

Training ProgrammeFATCA for LATAM Firms

23-24 February 2015 (Panama City), 25 -26 February 2015 (Santo Domingo)

Rodrigo ZepedaIndependent Consultant

Section 1: IRS Software Registration Portal

Section 2: Thomson Reuters FATCA Software

Section 3: Capgemini FATCA Software

Section 4: IBM FATCA Software

Section 5: Newgen FATCA Software

A Review of Existing FATCA Software Applications

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No. Software Application(s) Abbrev. Provider Abbrev.

1 FATCA Registration System IRS FRS U.S. Internal Revenue Service IRS

2 Thomson Reuters FATCA Compliance Solution TRFCS Thomson Reuters TR

3 PEGA 7 Platform PEGA 7Capgemini, Pegasystems & DLA Piper

CPD

4 IBM Operational Decision Management and Business Process Management

ODM & BPM IBM IBM

5 FATCA Compliance Software Solutions NFCS Newgen Software Newgen

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IRS FATCA Software Registration PortalSE CT ION 1

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IRS FATCA Registration System: Features

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IRS FATCA Registration System website (IRS FRS) is a web-based application containing the following features:

• Allows 24-hour-a-day, seven-days-a-week accessibility.

• Allows FIs users to establish an online account, including the ability to establish an access code and challenge questions.

• Ensures security for all data provided on behalf of FIs.

• Establishes a streamlined environment for FIs to register in one place.

• Provides FIs with tools to oversee member and/or branch information.

• Displays a customised home page for FIs to manage their accounts.

• Allows FIs to appoint delegates (Points of Contact) (POC) to perform registration tasks.

• Generates automatic notifications when a FI status changes (email notification to check FATCA account).

• Issues the Global Intermediary Identification Number (GIIN).

Under FATCA Withholding Agents (WAs) must withhold tax on certain payments to Foreign Financial Institutions (FFIs) that do not agree to report certain information to the IRSabout their U.S. accounts, including the accounts of certain foreign entities with substantial U.S. owners. A FFI may agree to report certain information about its account holders byregistering to be FATCA compliant. The FATCA Registration system is a secure, web-based system that Financial Institutions (FIs) may use to register completely online as aParticipating Foreign Financial Institution (P-FFI), a Registered Deemed-Compliant FFI (RDC-FFI), a Limited FFI (Limited FFI), or a Sponsoring Entity.

FATCA Registration can be accomplished most efficiently and effectively through the online registration process that will avoid the need to print, complete, and mail paper forms.This one-stop, electronic registration website presents a short set of questions about the registering FI its branches and Expanded Affiliated Group (EAG) Members. The registrationsystem can be accessed via www.irs.gov/fatca-registration. IRS Form 8957 instructions provide details about what information FIs require to register online. Paper registration formswill experience slower processing times and registrants will not receive a GIIN needed to demonstrate FATCA compliance until processing of their paper form is completed.

http://www.irs.gov/fatca-registration

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IRS FRS: FI Registration Process

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IRS FRS: FI Registration Process

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Overview of the IRS FRS registration process

• (1) Responsible Officer (RO); (2) Point of Contact (POC) (up to 5); (3) Authorized Third Party (ATP).

• Positive verification of Identity by the IRS for FFI Agreement signatories, i.e. electronic (social security number(SSN), individual taxpayer identification number (ITIN)), paper (Form 8956).

• POCs are only authorised to receive confidential tax information by the RO, they cannot sign the FFI Agreement.

• ATP is individual authorised by RO for registration and communications duties, e.g. signing the FFI Agreement.

• IRS FRS allows FIs to register as: (1) P-FFI; (2) RDC-FFI; (3) Limited FFI; or (4) a Sponsoring Entity.

• Details required for IRS FRS registration include mailing and physical address of FFI; date and country ofincorporation or organisation; FFI’s country of residence (tax purposes); list of all registering members of Lead FFI’sEAG; RO and POC details such as name, title, address, telephone, email.

• Registration is required for Model 1 Reporting FFIs, Model 2 Reporting FFIs, and RDC-FFIs in order to obtain a GIINand to authorise one or more POCs to receive information relating to FATCA registration on behalf of the FI.

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IRS FATCA Portal: Web Links for IRS Videos

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Creating a FATCA account for online registrationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=iIWVrk19QpA

Logging into a FATCA Accounthttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=UOC7jyY3CaQ

Recovering a FATCA ID or resetting a FATCA Access Codehttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=sDC3ne2-GUQ

Registration System Common Features and Navigationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=FEzSagUGte0

FATCA Registration Part 1 - How to Enter Financial Institution Informationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=97zXulSTA8Y

FATCA Registration Part 2 – Lead Financial Institution Enters Member Informationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=u2QU4RD2ZwA

FATCA Registration Part 3 - Lead Financial Institution: How to Enter QI / WP / WT Renewal Informationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=s6FOg-eC5EE

Lead Financial Institution: How to Manage Member Informationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=QAQQab4nnaU

Financial Institutions: Your Homepage Information and Optionshttp://apps.irs.gov/app/scripts/exit.jsp?dest=https://www.youtube.com/watch?v=yxTnSyi277w

FATCA Registration Part 4: How to Submit Registrationhttp://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=E-tVHFZWrrU

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=iIWVrk19QpA

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=UOC7jyY3CaQ

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=sDC3ne2-GUQ

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=FEzSagUGte0

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=97zXulSTA8Y

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=u2QU4RD2ZwA

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=s6FOg-eC5EE

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=QAQQab4nnaU

http://apps.irs.gov/app/scripts/exit.jsp?dest=https://www.youtube.com/watch?v=yxTnSyi277w

http://apps.irs.gov/app/scripts/exit.jsp?dest=http://www.youtube.com/watch?v=E-tVHFZWrrU

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IRS FATCA Portal: Outline

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Thomson Reuters FATCA SoftwareSE CT ION 2

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Thomson Reuters: Company Offering

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Thomson Reuters Overview

FATCA will have a significant impact on the compliance processes for thousands of organizations around the world, both financialand non-financial. It will transform the global tax framework and preparation because FATCA may become complex and arduous.

TR offer a full service solution for FATCA compliance that can be tailored to fit any size of organisation,wherever it is located and whatever the compliance challenges are. The TR for FATCA Compliance Solution(TRFCS) brings together market-leading products widely used by organisations around the world thatspan all obligations required by the new law including due diligence, withholding, customer identification,reporting and compliance management. Users benefit from our many years of experience and complianceexpertise so they can be confident that the components of the RF for FATCA Compliance Solution are triedand tested and used daily by thousands of organisations.

TR states that it is the world’s leading source of intelligent information for businesses and professionals. TR combine industryexpertise with innovative technology to deliver critical information to leading decision makers in the financial and risk, legal, tax andaccounting, intellectual property and science and media markets, powered by the world's most trusted news organisation. TR offersan integrated, modular solution – a convenient market leading software with intelligence databases and reporting capabilities.


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TR FATCA Compliance Solution (TRFCS)

The FATCA solution is comprised of the following components:

• ON-BOARDING

• GRANDFATHERED OBLIGATIONS

• WITHHOLDING & REPORTING

• KNOWLEDGE & LEARNING

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On-Boarding

TR Solution

• Facilitates rules-based FATCA client classification and identification aspart of the on-boarding process.• Tracks changes of circumstance to keep client profiles up to date.• Manages complex income beneficiary hierarchies and pass-throughstructures.• Tests for U.S. Indicia with a rule and data engine that analyzes customerdata and combines market leading information and complex matchingrules to identify a U.S. connection.• Collects W-8, W-9 and self-certification forms through an online taxdocumentation solution which gives a faster and more streamlined processfor obtaining, updating and reporting tax and self-certification forms.

Identify, Classify and CertifyRobust customer identification is not unique to FATCA, but a key element isthe gathering and maintaining of up-to-date documentation to support theprovisions in the identification of customers’ U.S. or non-U.S. status. Asoftware upgrade may be necessary for FFIs to support the level ofclassification and documentation handling needed for FATCA compliance.

Grandfathered obligations

TR FATCA Grandfathered Obligations (FATCA GO) solution:

• Combines market-leading content already widely used by organisations.• Gives access to a full securities report identifying which securities areeligible for exemption and which are grandfathered.• Provides a 3600 view, eliminating the need to create a developmentprogram to identify GO flags.• Filters over 3 million active records to determine which securities aregrandfathered.• Reports include: (1) reference data (GO and legal entity classificationsecurity IDs (CUSIP, ISIN)); (2) FDAP Flag (Y/N); (3) Grandfathered Flag (Y/N);and (4) FATCA Audit Field (attributes used for GO determination needed forreconciliation).• Powered by TR DataScope Suite.

TRDataScope Suite is a strategic data delivery platform for non-streamingcontent globally is a full cross-asset offering with intelligently linked data forall. TR DataScope content includes reference data, corporate actions, legalentity data, end-of-day and intraday pricing, and evaluated pricing services.

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Reporting

The TR FATCA Reporting Module offers complete datacollation, validation and submission for FATCA and IGAreporting as well as Management Information reporting,validation management and a full audit history.

The TR Reporting Module automates the creation and filingof reports based on the specifications dictated by each IGAcountry and the IRS (including electronic submission).

The tax information reporting landscape has changed substantiallyover the past two years and is set to become even more complex in thefuture. In order for FIs to deliver against regulatory requirements, arobust reporting system is required. Reporting requirements andelectronic schemas and formats will differ between countries, makingthe mechanics of formatting and filing data an onerous task. Datamanagement and processing will be a key issue as companies rise tothe challenge of managing different data transmission processes inmultiple jurisdictions.

Knowledge and e-Learning

TR Online Knowledge solutions track relevant regulatorychanges from national tax bodies, streamlining tax researchand providing expert analysis. Breaking news alerts analyze theimpact on your organization’s risk exposure.

TR eLearning solutions supports enterprise-wide FATCAeducation as well as specific jurisdictional and departmentalprograms. It drives active learning, retention, understandingand adoption, to ensure compliance at every level.

FFIs will need a governance system that provides for long-termsustainability. Data quality and integrity is crucial. It is necessary toknow which clients are U.S. persons, to ensure they sign a waiver toshare customer information with the IRS. Processes will need to be putin place to ensure that only information about U.S. persons is providedupon request and that data protection laws are not broken.

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Electronic W-8 and W-9 Forms

• Gathering IRS Forms W-8 and W-9 can be an onerousand time-consuming burden for organisations, which isprone to inaccuracies and intrusive for clients.

• Thomson Reuters Identity (TRI) simplifies andaccelerates the tax documentation process, by facilitatingthe collection, validation and maintenance of all Forms W-8 and W-9 online.

• TRI can also be used to gather forms designedspecifically for an individual client or industry grouping andother self-certifications that may be agreed by individualgovernments or the OECD.

• The IRS Memorandum of Understanding (MOU)process certifies the IRS’s recognition of the robustness ofan organisation’s W-8 and W-9 process. Thomson Reutershas been helping clients gain MOUs since 2009 and TRI isdesigned to facilitate this process.

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Thomson Reuters: Evaluation

Advantages

• A single point of reporting management for FATCA,IGAs and Common Reporting Standard (CRS) reports,to ensure consistent processes and managementcontrol.

• A robust system with an inbuilt and comprehensiveaudit trail, giving senior management and the taxauthorities’ confidence that the reporting process isconsistent and accurate.

• Fully managed and maintained content includingregular updates for schema, validation and rulechanges as they are introduced

• Flexible approach to source data means thatinformation can be uploaded from multiple sources inmany different formats, reducing the need for complexinternal IT re-work

• In-built validations and look-ups ensures that datacomplies both with schema requirements and otherbusiness rules and exception management

Disadavantages

• Customer sales support would not currently seem to beeffective.

• TR are relatively new to the market, and may not havethe long-term experience of other technology providerssuch as IBM.

• Customer IT, technology, and helpline support isuntested.

• Many different FATCA modules on offer may mean thatinstitutions may have either difficulty integrating all ofthem with existing systems, or may be costly toimplement all of them.

• TR solutions are orientated towards large financialmarkets such as the UK and the US, so likely tocurrently have only English language operationalsupport, not for example, 24 hour Brazilian or Spanishlanguage IT or helpline support.

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Capgemini FATCA SoftwareSE CT ION 3

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Capgemini: Company Offering

Capgemini FATCA Product: Pega 7 Platform

• A Comprehensive FATCA Solution - Capgemini, Pegasystems & DLA Piper.

• End-to-end automated legal, technology, software facilitating global FATCA compliance.

• To create a unique, end-to-end solution for FATCA compliance, Capgemini has partneredwith DLA Piper, a premier global business law firm with more than 4,200 lawyers in over30 countries, and Pegasystems, the recognised leader in business process management.

• Together they offer a service which aims to design, implement and assist cliens tosustain an end-to end compliance solution that addresses business, legal and ITrequirements for FATCA.

With almost 140,000 people in over 40 countries, Capgemini is one of the world's foremost providers of consulting,technology and outsourcing services. The Group reported 2013 global revenues of EUR 10.1 billion. Together with its clients,Capgemini creates and delivers business and technology solutions that fit their needs and drive the results they want. Adeeply multicultural organisation, Capgemini has developed its own way of working, the Collaborative BusinessExperienceTM, and draws on Rightshore®, its worldwide delivery model.

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Comprehensive Pega 7 Platform offering three elements

• Legal advisory services

DLA Piper will review client businesses, products, customers and geographies and advise on FATCA due diligencerequirements, exemptions, reporting, verification and withholding requirements. Since each company hasuniquely different issues when considering FATCA compliance, and may require advice on local law conflicts withFATCA, DLA Piper will also add customized legal advice to Pegasystem’s KnowYour Customer (KYC) solution.

• KnowYour Customer (KYC) Technology

Utilizes Pegasystems® KYC technology that includes core FATCA functionality including look-backmanagement and automation for pre-existing accounts; New account rules and due diligence requirements; Re-reviews based on change of circumstances; Automated indicia rating; Ability to apply the right FATCA rule basedon product, line of business, and geography; and Straight through processing based on exemption criteria.

• Integration and configuration services

Capgemini bridges the gap between defined business and legal requirements and technology through theirunique understanding of regulatory requirements that drive financial institutions, by coordinating andconfiguring client system interfaces into Pega’s KYC solution. This focuses the process of becoming FATCAcompliant through the development of a risk- based program that leverages your existing KYC data whileimproving and aligning your IT and legal capabilities specifically, while building efficiency into the process.

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Capgemini FATCA Product Technolgical Features

Proven. In enterprise-wide, transformational deployments in the world’s largest companies.

Complete. A unified platform able to deliver “end-to-end” customer experiences by integrating, automating and improving complex front- andback-office business operations.

Fast. 6.4x faster than Java Enterprise Edition to build robust business applications (Capgemini independent study).

Scalable. Build applications that meet the diverse needs of multiple business units, channels, products, geographies and customer segments.

Directly Capture Objectives™. Visual tools enable business-IT collaboration to deliver faster and more accurate applications.

Situational Layer Cake™. Pega 7 makes it dramatically easier to re-use common policies and procedures and apply them in multiple businessunits, channels, geographies and customer segments.

Omni-channel UX™. Pega 7 delivers an elegant and intuitive user interface that works across all channels, e.g. existing websites and mobile apps.

Case Lifecycle Management™. By organizing work by goals, stages, and steps instead of processes and transactions, Pega 7 manages the fullscope of work in a way that everyone can easily understand.

Next Best Action. Leverage big data, historical data and event streams to optimize the customer experience. Deliver the right action, offer or

information in real time across all channels.


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Processes

Outsourced Compliance Department SupportEffectively mitigate compliance risk by leveraging a unified process that provides scalability and sustainability. Capgemini can provide compliance support near-shore oroffshore using our Rightshore® model which puts the right people with the right skills in the right place.

System Implementation and IntegrationFIs must integrate legacy IT corporate information factory and customer data and banking systems to normalize data and create a multi-use centralised data repository.Capgemini can help plan and execute upgrades from first generation systems.

Independent Verification and ValidationRegulators are increasingly questioning whether FIs are conducting due diligence on implemented compliance solutions and whether the rationality in the decisionprocess is adequately documented. Capgemini can help validate and document your risk solutions by performing verifications such as process reviews or mapping.

Change Management Control ProcessCapgemini can review and develop change management policies and procedures and compliance program maintenance processes using industry best practices.

AnalyticsData analytics and metrics generated from KYC processes can be tuned through efficiency exercises and business intelligence efforts to support the compliance function.

RemediationFor regulatory and non-regulatory driven remediation, Capgemini can help you gather, review and provide quality control for KYC related information over a definedtimeframe to ensure compliance with regulatory requirements and quality of data.


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Advantages

• FATCA solution can be specifically tailored for a particularjurisdiction.

• Due diligence, legal, business process and otherrequirements are specifically taken into account.

• Developing a Business Application is 6.4 Times Faster inPega 7.

• Pega Enables Quick Creation of Branded Portals and UserInterface.

• Powerful Case Lifecycle Management.

• Predictive Analytics.

• Mobile Implementation.

• Pega Cloud and Pega Live Data.

• Pega Adapted to Changes 8 Times Faster.

Disadvantages

• Capgemini FATCA solution is relatively new, so it hasnot been tested commercially over a long period oftime.

• The Capgemini FATCA solution may be more expensivebecause it may rely on seeking specialist legal advicefrom operational lawyers as well as domestic lawyers.

• The new Capgemini FATCA solution may mean thatthere may be unexpected roll-out problems and delays,which may affect implementation lead-times anddeadlines.

• The availability and quality of IT, technology, andhelpdesk support is not generally known.

• Although Capgemini has offices in Argentina, Brazil,Chile, Guatemala, and Mexico, there may be no directlocal support available in other Latin Americancountries such as Bolivia, Colombia, Costa Rica,Dominican Republic, Panama, Paraguay, or Peru.

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Capgemini: Evaluation

4

IBM FATCA SoftwareSE CT ION 4

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IBM: Company Offering

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How IBM can help you prepare for and manage FATCA

• IBM helps FIs analyse FATCA requirements, design and build your FATCA implementation, and integrate it into your IT landscape.

• FIs can quickly start the business analysis needed to define the right work streams, start the project and move to implementation andreporting.

• IBM can streamline the implementation of a first prototype for client screening, allowing FIs to carry out impact analysis of processes andproducts, shareholding structure, value chain and partners, as well as IT architecture and interfaces.

• The Business Rules capabilities within IBM Operational Decision Management will be used to categorise clients and automate decisionswhile IBM Business Process Manager (i.e., Business Process Management (BPM)) will ensure efficient FATCA processes.

The value of a rule-based technology solution for FATCA and beyond• Business Rule Management (BRM) can efficiently screen all of the attributes related to clients, accounts and transactions, and generateautomatic reports.

• BRM allows FIs to make policy and decision changes quickly and safely, with transparency and unquestionable auditability.

• BRM and BPM can help FIs turn FATCA into a business opportunity.

• Due diligence will lead to much better understanding of your clients, resulting in more relevant product and services offerings.

• BRM allows FIs to balance the cost of FATCA due diligence with better client relationship management in day-to-day operations (e.g., usingBusiness Rules, you can decide who gets a letter and who needs to be contacted directly, with the potential to apply automated decisionmaking and support to other business requirements beyond FATCA).


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IBM Operational Decision Management and BPM

Ability to cope with a business logic that is:▪ Complex.▪ Ambiguous.▪ Ever changing.▪ Need transparency and agility.

Able to apply FATCA procedures:▪ Upgrade the existing processes.▪ Huge impact on workload.▪ Specific due diligence procedures.▪ Need to automate complex decisions.

Keep a good relationship with your client:▪ Negative presumption, investigation.▪ Reporting to the IRS.▪ Withholding.

Integrate your IT landscape:▪ Integrate into existing applications, e.g. account opening, payments.▪ Need for a service oriented approach.


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Advantages

• Unparalleled expertise and investment.

• Expert consulting and implementation servicesfor fast realisation of business value.

• Industry expertise to customize solutions foryour specific industry.

• Extensive customer base so can offer longevityand hands on experience.

• Number 1 in Business Rule ManagementSystems and BPM market share according to allleading analysts.

• Strongest Ecosystem and Partner Network

• 800+ Business Partners authorized and certifiedto support customers

• Strongest global ecosystem including majorglobal and regional system integrators skilled toprovide comprehensive solutions

Disadvantages

• Very large up-front investment for a specificFATCA compliance solution.

• Likely significant maintenance and futureupgrade costs.

• Possibility of complex system integrationinvolving significant business analysis andbusiness process analysis.

• May be more suited for larger Tier 1 and Tier 2banks, and less for smaller FIs such as smallhedge funds or small depositary institutions.

• If implemented across multiple jurisdictions mayresult in significantly longer lead andimplementation times.

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IBM: Evaluation

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Newgen FATCA SoftwareSE CT ION 5

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Newgen: Company Offering

Newgen Overview

• Software Products in Business Process Management (BPM).

• Enterprise Content Management (ECM).

• Customer Communication Management (CCM).

• 800+ ECM/BPM installations in 40 countries across Verticals.

• Over 150+ customer’s in banking, financial services, insurance.

• Over 100+ mission-critical processes deployments.

• Credited with some of the world’s largest implementations.

• Innovative culture, Consistent R&D investments, 35 patents.

• Certified for ISO 9001:2008, ISO 27001:2005 and CMMI Level3.

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Newgen’s FATCA Compliance Software (NFCS)

• Newgen aims to help organisations to gain FATCAcompliance through a thought leadership approach.

• Newgen offers integrated FATCA compliance software forFFIs and USFIs and concerned government agencies such astax authorities.

• NFCS helps FFIs create a step-by-step approach for acomprehensive compliance strategy.

• NFCS leverages Newgen’s two decades of domainexpertise in banking and compliance along with its marketleading BPM, ECM and CCM applications.

• NFCS makes astute use of Newgen’s Case Managementcapabilities alongside leveraging its business transformationplatforms, e.g. handling RAHs and maintaining scenario byscenario compliance adherence.


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Newgen FATCA Solution Suite for FFIs

Initiation: Integration of FATCA Solution to existing legacy system andamalgamation of information from new KYC Processes and pre-existingaccounts. Customer information prepared for Identification andClassification.

Classification: The aggregated data is subject to identification for USindicia checks to confirm U.S. or non-U.S. status.

Remediation: Workflow anchored case management process to easecomplex functions such as follow-up on accounts with missing orincomplete information. Ensure escalations or alerts if account holder isrecalcitrant or excepted.

Reporting: Helps creating and reporting information on U.S. accounts,account holders income, and other relevant reports demanded by IRSfor FATCA purposes. Also enables operational and investigativetransactional reporting for FATCA lifecycle management.

Decisioning: The solution helps with audit and document management,enabling recording and maintenance; reporting of account history forsuspect (or remediation) and recalcitrant customers. Enabling fasterresolutions and withholding. Helps maintain case by case records forfuture references demanded by IRS.


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Indicia Classification Rule Engine: Electronic W-8 and W-9 Questionnaires and Digital Forms, IRS Instruction Integration, GIIN validation.

Case Management, Exception Workflow and Reconciliation: To collate information on existing accounts to identify FATCA suspects.

Compliance Reporting : Forms 1042-S and 8966 as required under IGA, Internal Dashboards, auditing capabilities.

Multi-Channel Capture Tool for data, documents & form collection: Leveraging best-in-class document scanning and mobile capture features forany-time-any-where any point collection of FATCA information.

Electronic W-8/W-9 Questionnaires: Hosted on online portals for FATCA customer status self-certification. Questionnaires can help determine FATCAstatus as well as helping customers fill out W-8 and W-9 forms (e.g. GIIN validation, Substantial Presence test).

Digital W-8/W-9 Forms: Forms for Relationship Managers to capture and reconcilliate data provided by customers in physical and scanned forms.

NFCS

NFCS for USFI’s is an integratedyet modular solution to help FIsaddress the challenges associatedwith increased regulatorycompliance measures.


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NFCS for Government and Tax Authorities

NFCS for Government embodies extensive guidelines for all foreign governments and tax bodies to reportthe financial information of U.S. persons dealing with locally operating financial institutions. Thisinformation needs to be provided in the pre-defined Data Exchange Formats released by the IRS.Government agencies (e.g. tax authorities, central banks) must ensure a well-defined system of aggregatingdata, filtering and sending to the IRS. They will require an automated operating environment built onadvanced technology platform that provides a seamless reporting interface for all FIs and a robust dataexchange framework with the IRS.

NFCS for Government Agencies

NFCS creates an integrated system across all reporting touch points using organically developed tools (e.g.FATCA Identification, Classification and Reporting Engines; Business Rules Engine; Business ActivityMonitoring and Integration adapters). NFCS is a highly configurable and agile solution framework whichallows FIs to adapt according to the dynamically evolving FATCA mandates. Newgen is industry recognised,and boasts an award winning delivery model and inherent domain expertise.


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NFCS for Government Key Benefits

• Comprehensive end-to-end solution for FATCAreporting and compliance.

• Agile and flexible solution platform to adapt to anychanges in FATCA.

• Validations and Data verification capabilities.• Future ready solution for OECD’s Common

Reporting Standard (CRS) and other regulations.• Complete visibility and monitoring of all data

exchange.• Domain Expertise from leading FATCA Solution

provider with vast experience in FATCAimplementation.

• Comprehensive security framework for adherenceto IRS’s strict security and encryption standards.

• Solution available in multiple languages.


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Advantages

• Two decades of domain expertise in banking andcompliance along with market leading BPMapplications.

• Established and dedicated FATCA Centre ofExcellence.

• Differentiated FATCA compliance software forFFIs, USFIs and concerned governmentagencies.

• End-to-end Data Management.

• Extensive Reporting and Audit Capabilities.

• Error and Exception Management.

• Seamless Change Management.

• Robust Security.

Disadvantages

• NFCS is a relatively new solution for FATCAcompliance and has not been subjected toextensive and longitudinal testing.

• Newgen is a comparatively new entrant to thecompliance solutions market when compared toother technology firms such as IBM.

• Standardisation and global pervasiveness ofFATCA software solutions in the future maymean that more widely recognised compliancesoftware solutions become the standard marketsolution instead of Newgen.

• Newgen operates from its headquarters in NewDelhi, India, and therefore may have difficultiesproviding full scale IT, technology, and helpdesksupport for Spanish and Portuguese speakingLatin American countries.

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Newgen: Evaluation

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Presentation Information

DECLARATION OF CONFLICTING INTERESTSThe author declares that to the best of his knowledge he has no potential conflicts of interest with respect to the research orauthorship of this presentation.

ABOUT THE PRESENTERRodrigo Zepeda is an independent consultant who specialises in derivatives and financial services law, regulation, andcompliance. He holds a LLM Masters degree in International and Comparative Business Law, has been an Associate of theChartered Institute for Securities and Investment since 2004, and has passed the New York Bar Examination. He has alsopublished widely in leading industry journals such as the Capco Institute’s Journal of Financial Transformation, the Journal ofInternational Banking Law and Regulation, as well as e-books on derivatives law. Noted publications include “Optimizing RiskAllocation for CCPs under the European Market Infrastructure Regulation”; “The ISDA Master Agreement 2012: A MissedOpportunity”; “The ISDA Master Agreement: The Derivatives Risk Management Tool of the 21st Century?”; and “To EU, or not toEU: that is the AIFMD question”.

CONTACT DETAILSEmail: [email protected]: http://www.linkedin.com/in/rodrigozepedaMobile: UK + (0)7592457373

mailto:[email protected]

http://www.linkedin.com/in/rodrigozepeda

The Foreign Account Tax Compliance Act (FATCA)

Evaluative Case Studies on FATCA Implementation and Compliance SoftwareSESSION 8

Training ProgrammeFATCA for LATAM Firms

23-24 February 2015 (Panama City), 25 -26 February 2015 (Santo Domingo)

Rodrigo ZepedaIndependent Consultant