IEIM402780 - Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search

Where a Reporting Financial Institution fails to establish the residence of an individual with a Lower Value Account from the residence test [see IEIM402760], or is unable, or chooses not to apply the residence address test, it must review its electronically searchable data [see IEIM402300] for indicia of the individual’s residence (or, alternatively, citizenship for US reporting under FATCA). For FATCA reporting an electronic search may not be necessary if the Financial Institution has already established an Account Holder’s status in order to meet its obligations as a qualified intermediary [see IEIM402860].

The Account Holder will be regarded as a resident of a Reportable Jurisdiction [see IEIM402340] if any of the indicia below apply:

  1. The Account Holder is identified as resident of a Reportable Jurisdiction or as a US citizen [see IEIM402800].
  2. For FATCA only, there is an unambiguous indication of a US place of birth [see IEIM402820].
  3. The current mailing or residence address (including a post office box) of the Account Holder is in a Reportable Jurisdiction [see IEIM402840].
  4. There are one or more current telephone numbers in a Reportable Jurisdiction [see IEIM402844].
  5. Standing instructions to transfer funds to an account maintained in a Reportable Jurisdiction (For CRS only, other than a Depository Account) [see IEIM402847].
  6. A current effective power of attorney or signatory authority granted to a person with an address in a Reportable Jurisdiction [see IEIM402855].
  7. An “in-care-of” address or “hold mail” instruction in a Reportable Jurisdiction if the Reporting Financial Institution does not have any other address on file for the Account Holder [see IEIM402850].

If none of the above indicia are discovered through an electronic search, no further action is required in respect of Lower Value Accounts unless and until there is a subsequent change of circumstances that results in one or more of the above indicia being associated with the account or the Account Holder. Where such indicia arise the account becomes a Reportable Account unless the Financial Institution takes steps to cure or repair the indicia [see IEIM402880]. Only where the indicia remain in place after the cure or repair is completed will the account become a Reportable Account.

In addition, where a number of the above indicia are present but provide contradictory evidence the Financial Institution may take steps to cure or repair the indicia. For example, if the indicia, with the exception of a current telephone number in France, all point to the individual being resident in the UK, the Financial Institution can seek information from the individual to confirm where he or she is resident for tax purposes before treating the account as belonging to a French Reportable Person.

A Financial Institution will not be treated as having reason to know that that an Account Holder’s status is incorrect because it retains information or documentation that may conflict with its review of the Account Holder’s status if it was not necessary to review that information or those documents under the procedures for the electronic record search.

  1. IEIM402800
    Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search: Resident of a Reportable Jurisdiction
  2. IEIM402820
    Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search: Unambiguous US Place of Birth
  3. IEIM402840
    Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Records Search: Mailing or Residence Address