publicación acerca de la norma internacional sobre el intercambio automático de información, elaborada por la OCDE junto con el G20 y la colaboración de la Unión Europea.
Este informe pone de manifiesto los nuevos retos en materia regulatoria a los que se enfrentan las entidades financieras tras la adopción de la norma, con especial foco en el impacto que supondrá el cumplimiento de los requerimientos exigidos por el CRS.
201310 Risk Aggregation and Reporting. More than Just a Data IssueFrancisco Calzado
Many banks feel overwhelmed by the sheer volume of regulation that is coming their way. It is not surprising, therefore, that when the Basel Committee on Banking Supervision (BCBS) consultative paper, “Principles for effective risk data aggregation and risk reporting” was published in June 2012 it raised a number of concerns
Webinar: “Hospitals, Capital, and Cashflow Under COVID-19”PYA, P.C.
Hospitals and providers need to think creatively, strategically, and long-term about capital and cashflow under the pressures of the COVID-19 pandemic. A one-hour webinar hosted by PYA discussed the current state of capital markets for non-profit healthcare systems, and considerations for capital management, including the role of real estate assets.
PYA Principal Michael Ramey joined Realty Trust Group Senior Vice-President Michael Honeycutt and Ponder & Company Managing Director Jeffrey B. Sahrbeck to present “Hospitals, Capital, and Cashflow, Under COVID-19” In this webinar, they covered:
Hospital industry capital market updates and trends, including how the capital markets are responding to the crisis.
Access to capital under recent regulations.
Cash preservation techniques for hospitals considering real estate operations and assets.
The webinar took place Thursday, April 9, 2020, at 11 a.m. EDT.
The SEC & FINRA released their priorities for 2016 examinations. Asset management firms need to review + update their policies, procedures and business activities to reflect both sets of priorities so they can strengthen business practices and prepare for potential exams.
Healthcare organizations can no longer only focus on coding and billing compliance risks. Over time, compliance risk exposure has grown to include complex issues such as financial arrangements, real estate, cybersecurity, vendor management, and post-acute care services. It takes an active compliance program and effective risk management to survive the transformative shift that has taken place in the compliance landscape.
201310 Risk Aggregation and Reporting. More than Just a Data IssueFrancisco Calzado
Many banks feel overwhelmed by the sheer volume of regulation that is coming their way. It is not surprising, therefore, that when the Basel Committee on Banking Supervision (BCBS) consultative paper, “Principles for effective risk data aggregation and risk reporting” was published in June 2012 it raised a number of concerns
Webinar: “Hospitals, Capital, and Cashflow Under COVID-19”PYA, P.C.
Hospitals and providers need to think creatively, strategically, and long-term about capital and cashflow under the pressures of the COVID-19 pandemic. A one-hour webinar hosted by PYA discussed the current state of capital markets for non-profit healthcare systems, and considerations for capital management, including the role of real estate assets.
PYA Principal Michael Ramey joined Realty Trust Group Senior Vice-President Michael Honeycutt and Ponder & Company Managing Director Jeffrey B. Sahrbeck to present “Hospitals, Capital, and Cashflow, Under COVID-19” In this webinar, they covered:
Hospital industry capital market updates and trends, including how the capital markets are responding to the crisis.
Access to capital under recent regulations.
Cash preservation techniques for hospitals considering real estate operations and assets.
The webinar took place Thursday, April 9, 2020, at 11 a.m. EDT.
The SEC & FINRA released their priorities for 2016 examinations. Asset management firms need to review + update their policies, procedures and business activities to reflect both sets of priorities so they can strengthen business practices and prepare for potential exams.
Healthcare organizations can no longer only focus on coding and billing compliance risks. Over time, compliance risk exposure has grown to include complex issues such as financial arrangements, real estate, cybersecurity, vendor management, and post-acute care services. It takes an active compliance program and effective risk management to survive the transformative shift that has taken place in the compliance landscape.
Practice Valuation & Physician Compensation Planning ConsiderationsPYA, P.C.
PYA Principal Carol Carden and PYA Senior Consultant Katie Culver presented “Practice Valuation and Compensation Planning Considerations" at the TSCPA Southeastern Forensic & Valuation Services Conference.
Sustainable Growth Rate? Goodbye for Good!PYA, P.C.
PYA Staff Consultant Aaron Elias spoke to attendees of the Georgia Healthcare Financial Management Association’s (HFMA) Spring Institute May 6, 2015, on the implications of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
As today's not-for-profit organizations shift from being purely mission focused to operating more “like a business,” certain core principles and fundamentals apply to both. To wit, it is vital for audit committee members to stay ahead of relevant changes to legal and regulatory requirements in this challenging environment. Take a look.
Good Governance Practices for 501(c)(3) Organizations PYA, P.C.
PYA Tax Manager Elizabeth Wright presented “Good Governance Practices for 501(c)(3) Organizations” at the Accounting and Financial Women’s Alliance (AFWA) Luncheon in Knoxville, TN. The presentation provides an overview of good governance practices to assist any size 501(c)(3) organization in complying with IRS governance guidelines.
Accenture 2015 Global Structural Reform Study: Unlocking the Potential of Glo...Accenture Insurance
As they reshape the financial services industry in light of the 2007-2008 financial crisis, global regulators have introduced a series of structural reform regulations to help build resilience. Global Structural Reform (GSR) is creating a new financial services ecosystem for institutions.
Accenture’s 2015 Global Structural Reform Study finds senior management working to thrive in what amounts to an all-new financial services landscape. They are investing effort and funds in their response to GSR, but their focus is on meeting regulatory demands. While that represents a good starting point, our study finds institutions might be missing out when it comes to meeting the strategic implications of reform and using reform as an opportunity to reposition the organization for sustainable growth
Presentation Makes the Case for Enterprise Risk ManagementPYA, P.C.
PYA Principal David McMillan recently co-presented “Enterprise Risk Management” at the Massachusetts Continuing Legal Education 15th Annual Hospital & Health Law Conference.
Value enhancement at Canadian mid-sized FIsSohail_farooq
Small to mid-sized Canadian deposit-taking FIs are challenged from three different directions:
Competitive landscape, level playing field and profitability skew.
This deck reviews the challenges of the current operating environment for Canadian small to mid-sized FIs and provides tips on how to use strategic levers to be successful in this environment and what role can pricing analytics play.
Effect of Financial Reporting Quality on Corporate Performance Evidence from ...YogeshIJTSRD
This study determined the relationship between discretionary accruals, non discretionary accruals, on return on investment. Data for this study were obtained from secondary sources only. The study adopted an ex post facto research design. The secondary data were obtained from annual reports of 22 listed banks in Nigeria Stock Exchange. The sample banks were obtained using the stratified sampling technique while the sample size was obtained using the random sampling technique. The variables that were considered in this study are financial reporting quality and corporate performance, which were represented by the effect of discretionary accruals, and non discretionary accruals on return on investment. Data analyses were carried out using Ordinary Least Square statistical tools with aid of E view 9 and the level of significance used to test the hypothesis was 5 . The findings show that there is negative but significant relationship between discretionary accruals, non discretionary accruals and return on investment. Based on the findings, the study recommended that management of listed banks should ensure that they adopt best practices in financial reporting like Automated financial reporting solutions because there is direct relationship between abnormal accruals and return on investment. Anichukwu, Salome A | Ekwueme, Chizoba M "Effect of Financial Reporting Quality on Corporate Performance: Evidence from Listed Banks in Nigeria" Published in International Journal of Trend in Scientific Research and Development (ijtsrd), ISSN: 2456-6470, Volume-5 | Issue-3 , April 2021, URL: https://www.ijtsrd.com/papers/ijtsrd39835.pdf Paper URL: https://www.ijtsrd.com/management/accounting-and-finance/39835/effect-of-financial-reporting-quality-on-corporate-performance-evidence-from-listed-banks-in-nigeria/anichukwu-salome-a
Managing Costs Related to Increasing Banking RegulationCognizant
With banks' regulatory compliance challenges only increasing, they must find ways to reduce the associated legal costs, such as by using legal process services providers with experience in handling Know Your Customer (KYC), eDiscovery, foreign bank organizations, Deferred Prosecution Agreements (DFAs), non-prosecution agreements (NPAs), the Dodd-Frank Act and much more.
Depuis près de 10 ans, AMfine Services & Software développe et commercialise une gamme de logiciels et de services métiers à destination des acteurs de la Gestion d‘Actifs, de la Banque et de l’Assurance.
Leader sur la production documentaire réglementaire avec ses logiciels historiques, AMfine a su développer une offre globale répondant aux besoins des assets managers.
OFFRE CRS / FATCA
Automatic exchange of information (AEOI) - November 2016nztaxpolicy
Presentation delivered in November 2016 (Wellington - 4th November, Auckland - 9th November, webinar - 18th November) aimed at financial institutions and covered the practical implementation and technical issues for the Common Reporting Standard.
Substance as an important element of tax planning and global trends in exchange of information.
CONTENT
-Information exchange: general facts.
-AEOI: brief chronology.
-AEOI: general ideas.
-AEOI: scheme.
-AEOI: specifics.
-Practical example: Cyprus.
-What is “substance” and where does it come from?
-Today`s substance requirements.
-Actions and measures, indicating “substance”.
-Issues to be considered during the obtainment of Cyprus tax residency certificate.
-Questions asked by tax authorities investigating into substance over form.
Compliance Project Management -- Presentation at PMI Switzerlandsgarazi
After the global financial crisis of 2008, banks have been heavily pressured by governments and regulatory authorities to comply to new financial laws and regulations (Dodd-Frank Act, MiFID2, FIDLEG, ..). The FATCA legislation is active since 2014. The Automatic Exchange of Information (AEoI), building on FATCA, will become reality for Switzerland for most other clients on 01 January 2017! Others, such as MiFID2, are upcoming.
This presentation, held at PMI Switzerland on 01 November 2016, first provide the background of the financial crisis of 2008, then describes some of the regulatory responses that have been brought to it. Then, it dwells into the specificities of Compliance Project Management, the effective implementation of the regulations in banks.
Exchange on request, automatic exchange of financial account information and TRACE (Treaty Relief and Compliance Enhancement), spontaneous exchange of rulings, country-by-country reporting, voluntary disclosure programmes.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration and Monica Bhatia, Head, Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
Practice Valuation & Physician Compensation Planning ConsiderationsPYA, P.C.
PYA Principal Carol Carden and PYA Senior Consultant Katie Culver presented “Practice Valuation and Compensation Planning Considerations" at the TSCPA Southeastern Forensic & Valuation Services Conference.
Sustainable Growth Rate? Goodbye for Good!PYA, P.C.
PYA Staff Consultant Aaron Elias spoke to attendees of the Georgia Healthcare Financial Management Association’s (HFMA) Spring Institute May 6, 2015, on the implications of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
As today's not-for-profit organizations shift from being purely mission focused to operating more “like a business,” certain core principles and fundamentals apply to both. To wit, it is vital for audit committee members to stay ahead of relevant changes to legal and regulatory requirements in this challenging environment. Take a look.
Good Governance Practices for 501(c)(3) Organizations PYA, P.C.
PYA Tax Manager Elizabeth Wright presented “Good Governance Practices for 501(c)(3) Organizations” at the Accounting and Financial Women’s Alliance (AFWA) Luncheon in Knoxville, TN. The presentation provides an overview of good governance practices to assist any size 501(c)(3) organization in complying with IRS governance guidelines.
Accenture 2015 Global Structural Reform Study: Unlocking the Potential of Glo...Accenture Insurance
As they reshape the financial services industry in light of the 2007-2008 financial crisis, global regulators have introduced a series of structural reform regulations to help build resilience. Global Structural Reform (GSR) is creating a new financial services ecosystem for institutions.
Accenture’s 2015 Global Structural Reform Study finds senior management working to thrive in what amounts to an all-new financial services landscape. They are investing effort and funds in their response to GSR, but their focus is on meeting regulatory demands. While that represents a good starting point, our study finds institutions might be missing out when it comes to meeting the strategic implications of reform and using reform as an opportunity to reposition the organization for sustainable growth
Presentation Makes the Case for Enterprise Risk ManagementPYA, P.C.
PYA Principal David McMillan recently co-presented “Enterprise Risk Management” at the Massachusetts Continuing Legal Education 15th Annual Hospital & Health Law Conference.
Value enhancement at Canadian mid-sized FIsSohail_farooq
Small to mid-sized Canadian deposit-taking FIs are challenged from three different directions:
Competitive landscape, level playing field and profitability skew.
This deck reviews the challenges of the current operating environment for Canadian small to mid-sized FIs and provides tips on how to use strategic levers to be successful in this environment and what role can pricing analytics play.
Effect of Financial Reporting Quality on Corporate Performance Evidence from ...YogeshIJTSRD
This study determined the relationship between discretionary accruals, non discretionary accruals, on return on investment. Data for this study were obtained from secondary sources only. The study adopted an ex post facto research design. The secondary data were obtained from annual reports of 22 listed banks in Nigeria Stock Exchange. The sample banks were obtained using the stratified sampling technique while the sample size was obtained using the random sampling technique. The variables that were considered in this study are financial reporting quality and corporate performance, which were represented by the effect of discretionary accruals, and non discretionary accruals on return on investment. Data analyses were carried out using Ordinary Least Square statistical tools with aid of E view 9 and the level of significance used to test the hypothesis was 5 . The findings show that there is negative but significant relationship between discretionary accruals, non discretionary accruals and return on investment. Based on the findings, the study recommended that management of listed banks should ensure that they adopt best practices in financial reporting like Automated financial reporting solutions because there is direct relationship between abnormal accruals and return on investment. Anichukwu, Salome A | Ekwueme, Chizoba M "Effect of Financial Reporting Quality on Corporate Performance: Evidence from Listed Banks in Nigeria" Published in International Journal of Trend in Scientific Research and Development (ijtsrd), ISSN: 2456-6470, Volume-5 | Issue-3 , April 2021, URL: https://www.ijtsrd.com/papers/ijtsrd39835.pdf Paper URL: https://www.ijtsrd.com/management/accounting-and-finance/39835/effect-of-financial-reporting-quality-on-corporate-performance-evidence-from-listed-banks-in-nigeria/anichukwu-salome-a
Managing Costs Related to Increasing Banking RegulationCognizant
With banks' regulatory compliance challenges only increasing, they must find ways to reduce the associated legal costs, such as by using legal process services providers with experience in handling Know Your Customer (KYC), eDiscovery, foreign bank organizations, Deferred Prosecution Agreements (DFAs), non-prosecution agreements (NPAs), the Dodd-Frank Act and much more.
Depuis près de 10 ans, AMfine Services & Software développe et commercialise une gamme de logiciels et de services métiers à destination des acteurs de la Gestion d‘Actifs, de la Banque et de l’Assurance.
Leader sur la production documentaire réglementaire avec ses logiciels historiques, AMfine a su développer une offre globale répondant aux besoins des assets managers.
OFFRE CRS / FATCA
Automatic exchange of information (AEOI) - November 2016nztaxpolicy
Presentation delivered in November 2016 (Wellington - 4th November, Auckland - 9th November, webinar - 18th November) aimed at financial institutions and covered the practical implementation and technical issues for the Common Reporting Standard.
Substance as an important element of tax planning and global trends in exchange of information.
CONTENT
-Information exchange: general facts.
-AEOI: brief chronology.
-AEOI: general ideas.
-AEOI: scheme.
-AEOI: specifics.
-Practical example: Cyprus.
-What is “substance” and where does it come from?
-Today`s substance requirements.
-Actions and measures, indicating “substance”.
-Issues to be considered during the obtainment of Cyprus tax residency certificate.
-Questions asked by tax authorities investigating into substance over form.
Compliance Project Management -- Presentation at PMI Switzerlandsgarazi
After the global financial crisis of 2008, banks have been heavily pressured by governments and regulatory authorities to comply to new financial laws and regulations (Dodd-Frank Act, MiFID2, FIDLEG, ..). The FATCA legislation is active since 2014. The Automatic Exchange of Information (AEoI), building on FATCA, will become reality for Switzerland for most other clients on 01 January 2017! Others, such as MiFID2, are upcoming.
This presentation, held at PMI Switzerland on 01 November 2016, first provide the background of the financial crisis of 2008, then describes some of the regulatory responses that have been brought to it. Then, it dwells into the specificities of Compliance Project Management, the effective implementation of the regulations in banks.
Exchange on request, automatic exchange of financial account information and TRACE (Treaty Relief and Compliance Enhancement), spontaneous exchange of rulings, country-by-country reporting, voluntary disclosure programmes.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration and Monica Bhatia, Head, Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
Session by David Bradbury, Head, Tax Policy Statistics Division, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
Following on from the publication of the 15 point Action Plan on Base Erosion and Profit Shifting, the OECD and G20 countries released their first set of recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises. The OECD/G20 Base Erosion and Profit Shifting Project aims to create a single set of updated international tax rules to close the loopholes and gaps that enable multinationals to artificially shift profits and erode the tax bases of the countries where the economic activities generating those profits occur. In November 2014 the OECD released its new Strategy for Deepening Developing Country Engagement in the BEPS Project, which will strengthen their involvement in the decision-making processes and bring them to the heart of the technical work. The remaining set of deliverables will be finalized later this year.
On 21 July 2014, the OECD released the full version of the Standard for Automatic Exchange of Financial Account Information in Tax Matters. The Standard calls on governments to obtain detailed account information from their financial institutions and exchange that information automatically with other jurisdictions on an annual basis. The Standard was approved by the OECD Council on 15 July 2014 and was formally presented to G20 Finance Ministers in September. Already 93 jurisdictions have committed to early implementation of this standard by the end of 2018 and training is underway to ensure its effective implementation. Implementation of this Standard will truly mark the end of bank secrecy for tax purposes.
Automatic exchange of financial account information - March 2016nztaxpolicy
Presentation about New Zealand's proposed implementation of the GE20/OECD automatic exchange of information (AEOI) initiative.
Version for 14 March 2016 presentation at Inland Revenue, Wellington, New Zealand and 17 March 2016 audio conference.
For more information see:
http://taxpolicy.ird.govt.nz/topical-issues/implementing-aeoi
First came FATCA, now comes the Automatic Exchange of Information: is it just...sgarazi
Management of Regulatory Projects:
First came FATCA, now comes the OECD's Automatic Exchange of Information: is it just "copy & paste"? Which challenges exist?
COMMON REPORTING STANDARD (CRS). Powered by BGSM & PartnersPier Luigi Brogi
L'OCSE ha predisposto uno standard globale per lo scambio automatico di informazioni tra Paesi (Automatic Exchange Of Information - AEOI) basato sul modello introdotto dagli accordi intergovernativi (IGA) stipulati da diversi Paesi con gli Stati Uniti al fine di implementare la normativa statunitense FATCA.
Lo standard OCSE, definito Common Reporting Standard (CRS), prevede, al pari della normativa FATCA, lo scambio automatico annuale tra Autorità fiscali di informazioni fornite dalle istituzioni finanziarie di ciascun Paese.
Global and local Implementation
Timeline for early adopters
Integration of CRS into the Cyprus Tax National Law
Entity Classification
Reporting/Non-reporting Financial Institutions (FI)
Defining FI
Depository Institutions
Specified Insurance Company
Custodial Institution
Investment Entities
Defining Non-Financial Institutions (NFEs)
Active NFEs
Criteria of being considered a NFE
Based on Income and Assets
‘Substantially all ’ - Holding Company
‘Treasury Centre’ – Financing Company
Under CRS definitions & examples
Non-profit Organisations
Reporting and Timing
Sanctions for non-Compliance
Fund Regulation - Global Perspectives' Key Updates for 2015 GECKO Governance
This Fund Regulation 2015 update covers key updates from the main pieces of regulation impacting the investment fund industry this year.
Key regulatory updates include:
• AIFMD: update on Annex IV Reporting, Authorisation, Key dates in 2015
• FATCA: latest news from the IRS and key dates ahead, as well as CRS update
• UCITS V: progress on with implementation (remuneration & depositary) and key points to consider
• EMIR: latest requirements for reporting and implementation
• Solvency 2: impact on asset managers in the year ahead
• MiFID 2: update on MiFID reporting (MiFIR), fee disclosure and the impact on research
• How Global Perspectives can assist with your operational regulatory requirements
Contact us for more information:-
Shane@globalperspective.co.uk
Agenda
-Introduction to the Global Standard for Automatic Exchange of Financial Account Information - Commont Reporting Standards (CRS)
-Current Status of Commitments by 96 nations worldwide
-Lifting of bank secrecy and significant technical parametres of the CRS
-How to open bank accounts in alternative jurisdictions; Montenegro, Serbia, Bosnia and Georgia
Preparing for the OECD Common Reporting StandardCognizant
Maintaining planogram compliance enables retail organizations to better fulfill consumers' expectations and realize higher returns from their display investments by having the right product in the right place, in the right quantity, at the right price, at the right time.
A synopsis of the Financial Conduct Authority’s (FCA) latest news and publications issued in April and May 2018.
With GDPR and MiFID II processes now firmly embedded in our daily lives, many of our readers will look back at the months of April and May with a sense of relief.
Explain the relevance of a rate reconciliation in a tax provision. W.pdfrastogiarun
Explain the relationship between training and organizational development. How might each
contribute to strategic HR management?
Solution
Training plays a vital role in every Organization whether it is Private Limited firm or Public
Limited firm. In order to achieve desired targets of an Organization and also to make their
Employees to give better Productivity in Performance it is Imperative for an Organization to give
Training to their Employees whether it is Top Level of Management Employees or Bottom Level
of Management Employees. ( CEO\'s, Managers or Executives).
Giving Training to their own Employees and Performing good in their Desired Tasks gives Win-
Win Situation to particular Organization to function good in the Market against their
Competitors. Training their Employees for specific time duration For eg- 3 months can enable
Employees to perform for atleast 2-3 Years i.e. Short term Training with Long Term
Performance.
Training and Organization Management is very well connected with Strategic HR Management-
HR Recruits Employees and Training is also conducted from HR\'s only. If an Employees fails to
perform as per the targets decided from the Managers then Trainers communicates with HR
andaccordingly take actions to terminate Employees.
For Eg of my Own Firm where i work presently- Managers, training initiatives are focused on
providing them with the tools to balance the effective management of their employee resources
with the strategies and goals of the organization. Managers learn to develop their employees
effectively by helping employees learn and change, as well as by identifying and preparing them
for future responsibilities. Management development may also include programs for developing
decision making skills, creating and managing successful work teams, allocating resources
effectively, budgeting, business planning, and goal setting.
Conclusion-Training and development describes the formal, ongoing efforts of organizations to
improve the performance and self-fulfillment of their employees through a variety of methods
and programs. In the modern workplace, these efforts have taken on a broad range of
applications.
In this edition of Regulatory Focus, Duff & Phelps provides a synopsis of the FCA's latest news and publications issued in May 2017.
Highlights include:
MiFID II Topics and Challenges
FCA's increased focus on cyber resilience
Guidance on the Criminal Finances Act 2017
GAZT VAT guide on Financial Services - EnglishFarhan Osman
This guideline is directed for businesses involved in the Financial Services sector, including commercial banks, insurers, asset financing companies; or any business that provides financial services as part of its overall activities.
Automatic exchange of financial account informationnztaxpolicy
Presentation about New Zealand's proposed implementation of the GE20/OECD automatic exchange of information (AEOI) initiative.
Delivered on 7 March 2016 at Chartered Accountants Australia and New Zealand, Auckland, New Zealand.
For more information see:
http://taxpolicy.ird.govt.nz/topical-issues/implementing-aeoi
The biggest accounting changes coming out of the third quarter affected not-for-profit organizations, but other projects received minor updates, too. In addition, several exposure drafts have been issued, including the expected exposure draft of targeted improvements to hedge accounting.
Like the rest of the financial services industry, insurers are subject to increasingly complex and prescriptive regulations and standards. In the year ahead, insurers will need to focus on the new U.S.Department of Labor fiduciary standard, which is likely to have a significant effect on how insurance products are sold. Moreover, global developments, especially those related to the developing International Capital Standard, will require insurers to closely monitor – and ideally contribute to – official discussions about how globally active insurers should manage capital
In depth: New financial instruments impairment modelPwC
On June 16, 2016, the FASB issued Accounting Standards Update 2016-13, Financial Instruments – Credit Losses (Topic 326) (the “ASU”). The ASU introduces a new model for recognizing credit losses on financial instruments based on an estimate of current expected credit losses. The new model will apply to: (1) loans, accounts receivable, trade receivables, and other financial assets measured at amortized cost, (2) loan commitments and certain other off-balance sheet credit exposures, (3) debt securities and other financial assets measured at fair value through other comprehensive income, and (4) beneficial interests in securitized financial assets.
Similar to 201502 accenture automatic exchange of information regime an emerging compliance challenge (20)
La importancia de las personas en la era digital.
La habilidad de entender las cambiantes necesidades
y conductas de los clientes es, por supuesto, vital. Sin
embargo, el verdadero factor decisivo en la era de la
inteligencia será la habilidad de una empresa para
desarrollar su cultura corporativa con el fin no solo de
aprovechar las tecnologías emergentes, sino también de
abrazar las nuevas estrategias de negocio que impulsan
esas tecnologías.
Presenting the results of the 4th annual CIONET IT Trends, based on +2500 global responses, of which +800 European.
The study shows that, overall, IT is becoming more strategic and business focused. It appears that organizations are becoming more digitized with their focus shifting away from tactical and organizational IT issues like efficiency, service delivery, and cost reduction to more strategic and organizational priorities like business agility, innovation, the velocity change in the organization, IT time to market, and the value of IT to the business. Some suggest that IT is the business. Time will tell if this is a widespread trend, but it is here now among global and European organizations, and it is confirmed by a corresponding shift in how CIOs are spending their time.
Analytics/Business Intelligence (A/BI) remains in first place as the largest IT investment, a ranking it has held for six years straight. It has ranked in the top three since 2003, when it was first added to the list. A/BI was selected by 801 organizations
Comprehensive Report:
201501 Dynamic Pricing Policies and Active LearningFrancisco Calzado
El big data y la minería de datos son términos que están de moda y que básicamente reflejan la capacidad que se tiene en la actualidad de recopilar cantidades ingentes de información y extraer datos relevantes. Es una de las grandes tendencias que están transformando el mundo pero pocas veces se ve sus aplicaciones prácticas. Una de ellas es el establecimiento de precios dinámicos.
El dynamic pricing consiste en el ajuste dinámico de los precios de acuerdo con el valor que los clientes atribuyen a un producto o servicio, con el objetivo de maximizar los ingresos y el beneficio. Se trata de aprovechar la disposición al pago de ciertos clientes en determinadas situaciones para obtener mayores ganancias, y de aplicar descuentos en otras situaciones para generar crecimiento. Esto, que en principio parece una aplicación simple de la ley de oferta y demanda, hoy en día puede sofisticarse gracias a la informática y a las matemáticas para que las compañías logren la mayor eficiencia posible. Un artículo académico firmado por expertos de la consultora Conento explica los factores que se tienen que tener en cuenta para definir una estrategia de precios dinámicos y la base matemática que debe configurarse para hacer simulaciones y comprobar que funciona.
Ver informe
Hay una línea difusa entre lo que puede tener éxito en términos de precios dinámicos y lo que puede generar rechazo. Las cinco condiciones siguientes pueden ser determinantes a la hora de aumentar el beneficio de las compañías:
Los clientes tienen una disposición al pago variada. La disposición al pago (en inglés, willingness to pay, o WTP) es la cantidad máxima que el cliente está dispuesto a pagar por el producto o servicio. No es fácil de estimar.
Es posible segmentar el mercado, identificando diferentes grupos de clientes. En un evento deportivo o en un concierto, hay clientes que priman la localización de su entrada y otros que elegirían la entrada de menor precio.
El arbitraje debe ser limitado. Es decir, la posibilidad de reventa debe ser lo más reducida posible, como ocurre por ejemplo con los billetes de avión.
El coste asociado a la segmentación del mercado y a la diferenciación de precios no debe ser muy elevado. Así ocurre en el comercio electrónico.
Los clientes o compradores deben percibir equidad en el vendedor.
Un buen ejemplo del uso de precios dinámicos es Uber, startup que conecta pasajeros con conductores en más de 200 ciudades del mundo a través de una aplicación móvil. Según New York Magazine es una de las compañías que crecen más deprisa a nivel mundial y podría llegar a ser más valiosa que Facebook, y según MIT Technology Review su principal innovación es la utilización de un robusto sistema para establecer los precios de forma dinámica (por ejemplo, subió los precios en una tormenta de nieve en Nueva York durante las pasadas Navidades).
También hay
2. 2
What started off as a US initiative
to clamp down on US citizens
evading tax—by imposing a 30%
withholding tax penalty under the
Foreign Account Tax Compliance Act
(FATCA)—has spread and triggered
similar initiatives on a global level.
While financial institutions globally
struggle to meet the full FATCA
compliance requirements, they must
also deal with a wider global tax
transparency initiative introduced
by the Organisation for Economic
Co-operation and Development
(OECD) in the form of Common
Reporting Standard (CRS).
In February 2014, G20 finance ministers and
governors endorsed the CRS as the new
global standard for the Automatic Exchange
of Information (AEoI). On May 6, 2014, a
group of 441
countries (the early adopter
group) committed to a specific and ambitious
timetable to implement the new standard
with an effective date of January 1, 2016.
On July 21, 2014, the OECD released the
full version of the Standard for Automatic
Exchange of Financial Account Information
in Tax Matters, including the detailed
Commentary on the CRS, which was
endorsed by G20 members in the recent
summit, held on September 20-21, 2014.
At the OECD Global Forum meeting held on
October 29, 2014, fifty one jurisdictions*,
many represented at Ministerial level,
translated their commitments into action by
signing the Multilateral Competent Authority
Agreement that will activate automatic
exchange of information. A further 38
jurisdictions also confirmed their commitment
to start the information exchange by
September, 2018, and it is expected the
number will increase in near future.2
Like FATCA, CRS requires financial institutions
around the globe to play a central role
in providing tax authorities with greater
access and insight into taxpayer financial
account data, which means Customer Due
Diligence (CDD) and reporting obligations
are set to increase considerably.
Note: *The specific implementation schedule
outlined by the early adopter group is only
applicable to the original 44 jurisdictions.
3. 3
CRS is not the first initiative aiming to
achieve greater transparency and tackle
offshore tax evasion. The European Union
Savings Directive (EUSD) for automatic
information exchange has been in place
since 2005, although it is currently limited
to reporting certain types of interest income,
and not all EU member countries participate
fully. In March 2014, the EU agreed to an
extension to the existing EUSD to include
new types of savings income, products that
generate interest or equivalent income,
life insurance contracts and a broader range
of investment funds. The member countries
have until January 1, 2016 to adopt the
national legislation necessary to implement
the extended directive, which will take effect
on January 1, 2017. The EU has also proposed
to expand the scope of its 2011 Directive
on Administrative Cooperation (DAC), which
foresees, among other things, the automatic
exchange of information for the following five
categories of income: employment, director’s
fees, life insurance products, pensions, and
immovable property.
In the UK, financial institutions also need
to comply with the International Tax
Compliance (Crown Dependencies and
Gibraltar) Regulation 2014, which is widely
known as ‘UK FATCA’.
It remains unclear if there will be an
alignment and consolidation among these
various directives and regulations. Therefore,
a strategic response to the wider AEoI
regime is imperative to avoid skyrocketing
compliance bills and to minimize the
operational impact of these initiatives.
Financial institutions need to develop
strategies that meet compliance requirements
in a cost-effective manner while supporting
broader business objectives.
4. 4
CRS HAS A MUCH WIDER SCOPE
THAN FATCA
FINANCIAL INSTITUTIONS
• CRS has a broad definition of “financial
institution” which includes custodial
institutions, depository institutions,
investment entities and specified insurance
companies.
• Some low risk financial institutions carved
out of FATCA (such as building societies,
firms with a local client base, certain
investment funds, firms with only low
value accounts and sponsored investment
vehicles) are also included under CRS.
PRODUCTS
• The products in scope include depository
accounts, custodial accounts, cash value
insurance contracts, annuity contracts and
certain equity or debt interests.
• Certain insurance products (such as
pension funds) excluded from pre-existing
remediation under FATCA may come into
scope for CRS. In addition, equity interests
in investment banking exchange traded
funds are treated as financial accounts
under CRS.
DUE DILIGENCE
• Due diligence requirements increase
considerably due to additional
jurisdictions, a reduction of the de minimis
carve-outs and a requirement to look
through passive entities to report on the
ultimate beneficial owners.
• Due diligence is based on tax residency
as opposed to citizenship, which may
require updates to Know Your Customer
(KYC) systems.
INFORMATION REPORTING
• The financial information to be reported
includes all types of investment income
(including interest, dividends and income
from certain insurance contracts) but also
account balances and sales proceeds from
financial assets.
• Under FATCA, institutions were required
to identify and report US citizens only. CRS
seeks to implement a multilateral reporting
regime (44 jurisdictions to start with) with
‘bulk’ reporting of financial account data.
Figure 1: Scope of CRS
CRS
Compliance
Scope
Financial
Institutions
Products
Information
Reporting
Due
Diligence
Source: Accenture, November 2014
CRS is modeled on FATCA
principles and follows the same
staggered approach in terms of
obligations. There are, however,
underlying differences which,
coupled with a wider scope and
ambitious implementation timelines,
present a significant compliance
challenge for many financial
institutions. To prevent taxpayers
from circumventing the CRS, it is
specifically designed with a broad
scope across four dimensions
as seen in Figure 1 below.
6. CRS INTRODUCES EXTENSIVE DUE
DILIGENCE AND REPORTING OBLIGATIONS
CUSTOMER DUE DILIGENCE AND
CLASSIFICATION OBLIGATIONS
To identify and classify reportable
customers for all participating jurisdictions,
CRS introduces extensive due diligence
requirements. These procedures are different
for individual and entity customers and
also distinguish between pre-existing and
new accounts. To meet these requirements,
financial institutions must follow a
standardized approach with thorough due
diligence procedures while minimizing
downstream customer impact.
To limit the opportunities for taxpayers
to circumvent reporting by using interposed
legal entities or arrangements, the standard
also requires financial institutions to look
through shell companies, trusts or similar
arrangements, including taxable entities
to cover situations where a taxpayer seeks
to hide the principal but is willing to pay tax
on the income. Financial institutions will need
robust technical solutions to comply with
such extensive classification obligations.
PRE-EXISTING INDIVIDUAL
ACCOUNTS
As with FATCA, financial institutions are
required to classify their entire pre-existing
customer base for CRS; however, the de
minimis exemption has been removed.
Therefore, where previously institutions
were able to exclude a significant proportion
of their customer base by applying the
exemption, now they will need to carry out
appropriate due diligence procedures. This
implies that a larger proportion of customers
will need to be contacted to obtain self-
certification and/or documentary evidence.
For high-value accounts (that is, accounts
with an aggregate value of more than
$1 million), enhanced due diligence
procedures apply. These include both
paper-based reviews and a ‘reason to know’
relationship manager (RM) enquiry. Given
the number of jurisdictions involved, manual
enhanced review processes are expected to
be complex and have a downstream impact
on operational colleagues and RMs.
NEW INDIVIDUAL ACCOUNTS
CRS proposes self-certification for new
customers (customers on-boarded after the
CRS effective date), which require provision
of all tax residencies of the account holder.
This is different from FATCA, where the
confirmation of whether the account holder
is a US tax resident or not is sufficient.
Also, institutions are required to capture the
account holder’s date of birth, as well as the
Tax Identification Number (TIN) for all tax
residencies. Many institutions will have
to update their KYC systems and onboarding
forms to be able to capture the mandatory
data at the time of onboarding and record
it in a format which allows it to be used
for customer classification purposes by
the compliance rules engine.
The depository exemption for new bank
accounts has also been removed, which
will require additional customer contact
for self-certification purposes.
PRE-EXISTING ENTITY ACCOUNTS
Financial institutions are required to
determine whether the entity is a:
1. Reportable person, or
2. Passive non-financial entity (NFE)
Generally, the reportable status can be
determined based on anti-money laundering
(AML)/Know Your Business (KYB) or publicly
available information but where that is not
sufficient, self-certification is required.
Where the entity is a passive NFE,
the institution must determine the residency
of controlling persons. This information may
not be available in existing KYB data and
hence a self-certification will be required.
If allowed by domestic law, entity accounts
below $250,000 can be excluded from
review until the balance exceeds the
$250,000 threshold at the end of the
calendar year. This is different from FATCA,
where the balance threshold is $1 million.
Therefore, under CRS, a greater number
of entities will fall in scope of review.
NEW ENTITY ACCOUNTS
As is the case with pre-existing accounts,
financial institutions are required to
determine whether the account is held by one
or more reportable persons or by a passive
NFE with one or more controlling persons
that are reportable persons. There is no need
to determine any other status (such as FATCA
partner financial institution, a participating
foreign financial institution (FFI), a deemed-
compliant FFI, or an exempt beneficial owner).
As it is easier to obtain self-certification
from new customers at the time of
onboarding, the $250,000 threshold has
been removed, and institutions are required
to determine the tax residency of all
controlling persons of passive NFEs.
Institutions may also want to extend these
due diligence requirements to capture
multiple tax residencies for pre-existing
accounts. This may significantly reduce the
cost of fresh due diligence for each new
country which joins the CRS regime.
OBLIGATIONS FOR CHANGE
OF CIRCUMSTANCES
As with FATCA, financial institutions are
required to identify and react to any
change, addition or removal of information
to customer accounts or any associated
account. Therefore, institutions must
implement internal controls, systems and
processes to monitor, track and react to any
change in circumstances.
A change in circumstance is only relevant
if it affects the reportable status of the
underlying customer. For example, a change
in telephone number or address details within
the same jurisdiction will not result in any
change for reporting purposes. Therefore,
institutions will need to implement low-
impact detection methodologies to only react
to changes which affect reporting status.
If a change in circumstance causes the
financial institution to know, or have reason
to know, that the existing documentation is
unreliable, then it must contact the customer
to obtain a new self-certification to establish
the tax residency.
6
7. If a customer fails to respond to a self-
certification request, the institution
must treat the customer as reportable
for jurisdictions where it has indicia on
record (such as tax residency or current
residential address in a reportable
jurisdiction) or has reason to know, until
it is given the necessary information.
REPORTING OBLIGATIONS
CRS introduces a comprehensive reporting
regime covering all types of investment
income (including interest, dividends,
income from certain insurance contracts
and other similar types of income), and
also addresses situations where a taxpayer
seeks to hide capital that itself represents
income or assets on which tax has
been evaded (for example, by requiring
information on account balances).
Financial institutions must report the following
information for each reportable account:3
1. Name, address, TIN and date and place
of birth (in the case of an individual) of each
reportable person that is an account holder
of the account. In the case of an entity where
one or more controlling persons is identified
as reportable, the institution must report the
name, address, and TIN of the entity and the
name, address, TIN and date and place of
birth of each reportable person.
2. The account number (or functional equivalent
in the absence of an account number).
3. The name and identifying number (if any)
of the reporting financial institution.
4. The account balance or value (including, in
the case of a cash value insurance contract or
annuity contract, the cash value or surrender
value) as of the end of the relevant calendar
year or other appropriate reporting period;
or, if the account was closed during such year
or period, the closure of the account.
5. In the case of any custodial account:
a) The total gross amount of interest,
dividends and other income generated
with respect to the assets held in the
account, in each case paid or credited
to the account (or with respect to the
account) during the calendar year or
other appropriate reporting period; and
b) The total gross proceeds from the sale or
redemption of property paid or credited
to the account during the calendar year
or other appropriate reporting period
with respect to which the reporting
financial institution acted as a custodian,
broker, nominee, or otherwise as an
agent for the account holder.
6. In the case of any depository account,
the total gross amount of interest paid or
credited to the account during the calendar
year or other appropriate reporting period.
7. In the case of any account not described
in section 5 or 6, the total gross amount paid
or credited to the account holder with respect
to the account during the calendar year
or other appropriate reporting period with
respect to which the financial institution is
the obligor or debtor, including the aggregate
amount of any redemption payments made
to the account holder.
The reporting challenge may appear
far off with the obligation to file CRS
reports annually, starting September 2017
(covering the previous calendar year).
However, since many organizations are in
the process of defining their solution for
FATCA reporting, it is imperative that the
CRS requirements be taken into account
to minimize future compliance costs.
The early adopter group of 44 countries
has outlined an ambitious implementation
roadmap (as shown in Figure 2 below) for
these obligations. This is likely to present
a serious challenge for many organizations.
In our view, financial institutions will need
to act quickly to define their CRS compliance
operating model and should allow sufficient
time for implementation and delivery of the
underlying technical solution.
Figure 2: CRS Compliance Timetable
CRS Compliance
1. Effective Date
January 1, 2016
Required by obligation
*HV = High value customers
CRS Compliance Implementation timeline outlined by the early adopter group
Source: Accenture, November 2014
Note: Timelines are based on the joint statement by the early adopters group released in August, 2014. Access at: http://www.oecd.org/tax/transparency/AEOIjointstatement.pdf
January 1, 2016 January 1, 2016 December 31, 2016 (HV*)
– December 31, 2017
(Non-HV*)
September, 2017
onwards
2. Governance
and Compliance
3. New Customers
(Onboarding, identification
and classification)
5. Reporting4. Pre- existing
Customers (Identification
and classification)
7
8. WHAT DOES THIS MEAN FOR FINANCIAL
INSTITUTIONS NOW?
Figure 3: CRS Compliance RequirementsFinancial institutions will need
to assess if the processes and
solutions defined for US FATCA
are able to accommodate the
additional requirements of CRS
and to determine if, in the longer
term, there are more efficient ways
to organize, consolidate specific
capabilities to minimize operational
costs, and generate benefits for
the business. From a capability
perspective, the CRS compliance
requirements can be summarized
in the four areas shown in Figure 3.
KNOW YOUR CUSTOMER
Successful classification and reporting
comes down to the efficiency of onboarding
collection. From a data management
perspective, banks need to ensure that they
are accurate on the first attempt, and avoid
the problem of incorrect reporting. For the
attributes and data that firms now gather
at source—or need as output for classification
or reporting—there should be definitions,
data quality standards, guidance, and an
understanding by the staff of the importance
of high quality data. In that respect, KYC is
a critical piece and one which will heavily
influence the customer classification and
reporting design.
Financial institutions may have to update the
existing KYC and client onboarding systems
and procedures to be able to capture and
record additional data such as multiple tax
residencies and tax identification numbers.
Institutions should consider the impact on the
overall customer experience and try to keep
requests for information to a minimum, while
seeking to minimize the future changes and
operational impact of the design. For most
organizations, the key would be to assess
to what extent the customer onboarding
operating model designed for FATCA can
be leveraged for CRS.
Given the wide scope of jurisdictions and
removal of some of the de minimis exemptions,
a higher number of customers will be subject
to due diligence procedures, and additional
customer contact will be required to obtain
necessary self-certification.
Institutions need to define the appropriate
self-certification procedures and implement
systems to manage the workflow and
systematically record this information.
This information can then be accessed by
the compliance rules engine for customer
classification. The ability of firms to properly
process information from documentation
is essential. Firms can staff up to execute this
manually, but having tools and technologies
to automate this activity can be a huge
benefit, especially for larger organizations.
Organizations will also have to decide
whether they want to develop a central
shared services model for self-certification
management or manage it locally on
a business unit basis. Developing a centralized
capability can help establish standardized
processes, controls and colleague training,
and future changes to self-certification
forms should be easier to manage compared
to implementing the change across several
business units. However, the centralized
operation may require establishing a new
team. The greater the number of expected
self-certification requests, the greater the
volume of processing and subsequent full-
time equivalent requirements, which will be
a key decision factor in the overall design.
If a single processing center is created,
the servicing of multiple jurisdictions
(depending on data protection requirements)
may either need to be performed by a
dedicated team (with increased security
standards) or it may need to be sited
exclusively within the given jurisdiction.
Source: Accenture, November 2014
CRS
Compliance
Management
Information
and Reporting
Compliance
Rules Engine
Compliance
Data Store
Know Your
Client
8
9. COMPLIANCE DATA STORE
Data gathering, integration and the alignment
between the client data and the product
data is perhaps the biggest challenge for
financial institutions. Traditionally, data
gathering and integration has been very
focused on Standard Settlement Instructions
(SSI); as long as firms captured settlement
instructions, they were able to get the
payment out the door, and the transaction
was complete. Now, however, they need
to use both transactional and counterparty
information which has traditionally reposed,
respectively, in account and client databases.
Firms need to create a single client view and
therefore need to move from a product view
to a client view.
The second challenge is determining how firms
will evidence that they are compliant, with
a clear audit trail. The problem is no longer
merely capturing and processing the data; the
data must also be stored and retained for audit
and evidentiary requirements. This will require
more space as well as better integration with
current processes.
Firms may want to explore a meta-data
driven approach that keeps some of the
data where it lives, but creates a more unified
view holding only the key data elements
in a centralized location. This serves
as a “compliance data store”.
COMPLIANCE RULES ENGINE
CRS compliance requires the implementation
of a complex regulatory rule engine, which
can analyze the customer data and classify
the customer as either reportable or non-
reportable for each participating jurisdiction.
Any attempt at a standardized approach to
classify account holders will be complicated
due to differences among CRS, FATCA, Crown
Dependencies and Overseas Territories (CDOT)
agreements, the EUSD and—should the
proposed amendments be agreed—the DAC.
Moreover, under CRS, each time a new
country joins, institutions in participating
jurisdictions will have to undertake due
diligence procedure for back-book customers
to identify reportable accounts for the new
reporting jurisdiction. Therefore, scalability
and “future proofing” are crucial to reduce
the ongoing cost of compliance.
The higher volume of customers subject to
due diligence means that those firms which
adopted tactical or localized classification
procedures for FATCA will now have to invest
in robust technical solutions to reduce the
operational impact. They must also be able
both to remediate the pre-existing accounts
and to classify new accounts.
MANAGEMENT INFORMATION
AND REPORTING
Because there are multiple reporting regimes
running in parallel, financial institutions (FIs)
are now challenged by the “multiplicity” effect
of reporting, which will increase depending
on how many jurisdictions an FI has to deal
with, and the approaches to data classification,
customer engagement and reporting.
Differences between FATCA and CRS means
the FIs may not be able to use the same
reporting procedures for both standards.
FIs with a significant customer base outside
their home country, will be reporting big
volumes of data to local tax authority under
CRS and therefore manual or semi-manual
solutions will need to be reappraised.
The complexity of CRS reporting stems
primarily from the level of granularity
and extent of information to be reported,
coupled with the high quality of report
submissions that will be expected by local
tax authorities. Bulk transfer of customer
financial account information will also raise
data security and privacy concerns, calling
for robust tracking mechanisms.
CRS allows additional due diligence and
reporting requirements to be initiated
bilaterally between reportable countries,
which will also significantly increase the
complexity of the reporting solution.
Parallel to reporting, financial institutions
will need robust completeness checking and
reconciliation solutions to support internal and
external audit and evidentiary requirements.
The key assurance that institutions will need
to provide to auditors, tax authorities and
regulators is the proof that every single pre-
existing and new customer has been classified
for each participating jurisdiction and
appropriate due diligence procedures have
been carried out. Providing such assurance
will not be easy and will likely require
an effective technical solution.
9
10. ACCENTURE’S PERSPECTIVE ON CRS
CRS is not a mere extension
of FATCA and presents a significant
compliance challenge for many
organizations. A conscious effort
is required to develop a strategic
response to the wider AEoI regime,
both to avoid enormous compliance
bills and to minimize the impact
on customers and operations.
CRS is not ‘FATCA version 2.0’ and has
a much wider scope in many respects.
Financial institutions that took a tactical
approach to FATCA compliance—either by
creating manual processes or by terminating
business with US clients—need to reappraise
their approach to compliance with CRS.
As a result of the removal of some of the de
minimis exemptions and the greater number
of participating jurisdictions, CRS requires
institutions to remit a greater number of
accounts, contact additional customers,
and report a larger number of customers
with additional information. As a result,
institutions may not be able to use the same
solutions for FATCA and CRS. In the UK,
FIs will have to report under the CDOT and
potentially the revised EUSD as well, which
will further complicate the solution. At this
stage it is unclear how different reporting
regimes will co-exist or if there will be
a convergence of these standards.
CRS programs will be inherently complex
in nature given the range of obligations,
the relatively tight timescales and the
instability of requirements. The tools, analysis
and learnings from FATCA can provide the
starting baseline; however, the differences
are so profound that new processes, controls
and systems will inevitably be required. All
this is taking place in an intense regulatory
environment which will place great demands
on already constrained delivery resources.
Sourcing the required subject matter
expertise will be a key challenge.
A strategic technical response is critical
to meet compliance with AEoI emerging
regulations and to reduce the cost of future
compliance when new countries come on
board or introduce their own version of
FATCA. A sustainable and flexible
IT architecture should mean that institutions
are prepared for new countries joining, or for
evolving CRS requirements.
Some key considerations for a successful
CRS program include:
Future proofing and scalability. FATCA and CRS
are setting the scene for a wider global tax
transparency system, so institutions need
to ensure that their IT solutions are scalable
and the focus is on the ‘intent of the law’ as
opposed to the ‘letter of the law’ to achieve
sustainable compliance.
Managing overlapping and conflicting
regulatory obligations and timelines.
Financial institutions are dealing with
a number of regulations affecting the same
underlying capabilities. For example, the KYC
and onboarding capabilities are affected by
European Market Infrastructure Regulation
(EMIR), the Dodd-Frank Act, the Markets in
Financial Instruments Directive (MiFID) and
the Alternative Investment Fund Managers
Directive (AIFMD). While these regulations
are different in purpose, scope and technical
requirements, they all necessitate efficient
and up-to-date, client data processes.
Financial institutions should seek to
identify synergies between other regulatory
programs across key capabilities to
establish a single change portfolio to
overcome challenges related to resources,
budget and future proofing, and to
minimize the number of times the bonnet
must be raised to implement change.
Dealing with tight timetables. CRS delivery
schedules are demanding, especially when
balanced with other regulatory demands.
However, the obligations for KYC, due diligence
and reporting are staggered over the next few
years. Therefore, institutions should ensure
that any delivery strategy allows for individual
obligation timelines to be met rather than
packaging delivery into one drop with no
subsequent flexibility to phase in as required.
Consistency of interpretation and application.
Institutions with many business units,
operating across multiple jurisdictions should
ensure consistency of interpretation and
application of the regulation. These firms
should consider a centralized program team
driving interpretation, rule book creation and
a standardized operating model. These can
then be tailored to local needs if applicable.
Data remediation and quality control. Financial
institutions are likely to face their biggest
challenge in the data gathering and integration
space. They should, therefore, not undermine
the data remediation work that may be required
by starting late. Organizations should conduct
a strategic review to assess the benefits of
establishing or broadening the single customer
view across the organization and weigh it
against the effort required to develop localized
solutions to make an informed decision.
Establishing a robust control environment.
Institutions should agree, as early as possible,
upon the principles for management of the
ongoing compliance and maintenance of the
control environment across the organization,
including policies, standards and procedures.
Ownership, lines of control and responsibility
should also be determined. Where possible,
firms should try to leverage existing control
environment structures.
Considering custom versus packaged solution
options. Institutions should consider
the benefits of a vendor-packaged solution
for compliance rules engine and regulatory
reporting versus an internal custom build.
The key factor driving the decision will be
the solution’s ability to leverage and extend
the existing KYC/AML/FATCA platforms.
Considering the wider benefits of the CRS
program. The costs of compliance can
be high, depending on the make-up of the
organization. Considering the wider benefits
of CRS change can enhance the business
case. These include the benefits of further
centralization and remediation of customer
data and the opportunities that CRS change
can provide the AML/Sanctions team.
Establishing and maintaining operational
expertise. Across the organization, operational
expertise for CRS will be a challenge.
A successful implementation will require
subject matter experts in CRS legislation, tax,
legal and risk, as well as a strong, centralized
delivery team. Firms should consider
centralization of this knowledge and expertise
in a CRS Center of excellence.
10
11. HOW ACCENTURE CAN HELP
Accenture has extensive regulatory
change management and delivery
experience and has helped many
global financial institutions with
their FATCA programs. We can help
conduct the feasibility studies
to identify detailed functional and
technical requirements, and help
define the appropriate compliance
strategy to minimize the impact
and cost to the business.
Accenture has developed a comprehensive
review of the new CRS regulatory
requirements. This review covers changes
related to due diligence, classification and
reporting and also includes a comparison
with FATCA requirements across these
capabilities. To respond to the new regulatory
requirements, we have also developed
a target IT architecture framework design
as seen in Figure 4 below.
The sample IT design includes a new
compliance rules engine, which can help
clients address all functional and technical
business requirements and also helps:
• Support the customer onboarding process
by performing all new functionalities
required for customer identification
and classification (both for pre-existing
and new customers).
• Interact with legacy systems to collect
the data required for classification
and reporting.
• Determine the final CRS status for each
customer and manage the self-certification
workflow.
• Report the required customer information
to local tax authority and provide a robust
reconciliation solution.
Accenture has FATCA solution design and
delivery experience in over 14 jurisdictions,
which can be leveraged to analyze an
existing FATCA solution and build a strategic
response to CRS in a pragmatic and cost
effective manner. We understand the wider
regulatory landscape and can help deliver
a consolidated compliance transformation
program to help minimize the overall
compliance cost. Moreover, we have strong
industry alliances with third party vendors
and can help select and implement the right
vendor solution for your organization.
Figure 4: Accenture’s Perspective on an Architecture Compliant with the AEoI Regime
Source: Accenture, November 2014
Customer Due Diligence
Securities Cash Account Other Payments
Compliance Rules Engine
(Customer Identification and Classification)
Self-certification Engine
(Electronic document storage and processing)
Product Blueprint
Management Information
and Reporting
Workflow Management
AggregatedPositions
AEoI Regulatory Reporting Engine
Customer’s Master Data
Data Management
• Customer identification
• Pre-existing account
due diligence
• Periodic reviews
• Product classification
• Accounting and
balance information
• Customer data and
transaction reporting
• Reconciliation and
completeness checking
• Document management
system
• Compliance data store
Existing application
Onboarding PlatformAML/CDD
Enhancements/new logical modules
11