The world of financial compliance is bracing itself for the onslaught of new regulations that promise to have a substantial impact on the operational efficiencies and costs associated with serving new and existing clients. If 2012 was the year of delayed regulation, you can bet your last pound, euro or dollar that 2013 will be the year of enforced regulation.
The challenge for compliance and onboarding teams will be how to manage all of these regulations – each with their own specific data, processes and technology nuances – to ensure full compliance that does not impinge on client satisfaction or experience? The biggest problem at the moment is the state of limbo that every financial institution finds itself in as they await final regulations to be put into place.
In this whitepaper, author and FATCA Subject Matter Expert with Fenergo, Fiona Cummins, explores some of the findings from the recent FATCA survey that Fenergo conducted in September 2012 – prior to the announcement of the revised FATCA deadline. Despite the deadline delay, it is heartening to note that most financial institutions are continuing to push ahead with FATCA preparations to maintain the momentum gained in the lead up to the original FATCA implementation and compliance dates.
A number of themes emerge from the survey findings:
- FATCA will have a significant impact on processes and procedures, with CDD / KYC impacts and the decision to keep or terminate relationships with US clients topping the change management agenda
- While many Foreign Financial Institutions (FFIs) have embarked on their FATCA journey by examining their client identification processes, issues around data quality and siloed repositories are making the electronic search for FATCA-liable clients more difficult.
- Over 70% of FFIs are treating FATCA as a separate project to other compliance regulations and have secured a specific budget for it, with the majority being allocated to IT requirements, client documentation, and client identification processes.