IEIM403200 - Due Diligence: New Individual Accounts: Self Certifications: Change of Circumstances

Due Diligence: New Individual Accounts: Self Certifications: Change of Circumstances

A self-certification can become invalid as a result of a change of the Account Holder’s circumstances [see IEIM403020]. Reporting Financial Institutions need to have procedures to ensure that any change that constitutes a change in circumstances is identified.

A Reporting Financial Institution is expected to notify any person providing a self-certification of the person’s obligation to notify the Reporting Financial Institution of a change in circumstances.

A change in circumstances affecting the self-certification provided to the Reporting Financial Institution will invalidate the self-certification with respect to the information that is no longer reliable until the information is updated.

A self-certification becomes invalid as soon as the Reporting Financial Institution knows or has reason to know that circumstances affecting the correctness of the self-certification have changed. However, a Reporting Financial Institution may treat the status of the Account Holder as unchanged until the earlier of:

  • 90 calendar days from the date that the self-certification became invalid due to the change in circumstances;
  • the date that the validity of the self-certification is confirmed (where appropriate); or
  • the date that a new self-certification is obtained.

A Reporting Financial Institution may rely on a self-certification without having to inquire into possible changes of circumstances that may affect the validity of the statement, unless it knows or has reason to know that circumstances have changed.

If the Reporting Financial Institution cannot obtain a confirmation of the validity of the original self-certification or a valid self-certification during the 90-day period, the Financial Institution must continue to treat the Account Holder as resident in the jurisdiction identified in the original self-certification and must also treat the Account Holder as resident in the jurisdiction indicated by the change of circumstance.