The document outlines the necessary steps for enterprises to achieve compliance with FATCA regulations, emphasizing the need for meticulous planning and specialized roles. It discusses various components of a FATCA-compliant framework, including data capture, review processes, monitoring, and audit management, alongside the flexible adaptability of systems to accommodate future regulatory changes. A robust information management system is highlighted as essential for ensuring compliance while maintaining operational efficiency.

1. As we fast approach the stipulated timelines associated with FATCA, enterprises worldwide need to quickly
get their acts together and redesign all processes to adhere to the various regulatory mandates. This
enterprise wide change has to be planned meticulously, ensuring business as usual doesn't suffer any
major jolts in the process.
Approaching FATCA as just another reporting exercise is a short-sighted approach that may lead to
complexities in future. Achieving compliance in a comprehensive manner will require specialized roles and
processes to be created, facilitated by an extended information gathering mechanism built on an efficient
Information Management System.
Are you ready for FATCA?
Overview
STAKES
ARE HIGH
REPUTATIONAL RISK
FINANCIAL RISK
OPERATIONAL RISK
FATCA
What is needed to be FATCA Compliant - A Readiness Checklist
What is
needed
Why is it
needed
How do we
accomplish this
Core
Banking
System
Newgen
FATCA
Solution
Data Capture To capture FATCA related
additional KYC data fields for
identification of customer
status as per regulatory
guidelines
Template driven data capture
to ensure capturing of all
data fields that users would
need not only for FATCA but
also for KYC and other
regulatory norms.
Yes Yes
Rules for Indicia
Identification,
Classification and
Aggregate
balance checks
FATCA is a regulatory
framework that needs accuracy,
timeliness, standardization and
consistency in meeting the
process guidelines. FATCA
doesn't allow manual errors and
judgment related leakages to
lead to Non-Compliance based
risks.
Pre-defined and user-
configurable business rules
framework helps define
customer classification rules
based on US indicia and
threshold limits while
adapting to internal KYC
processes.
Partially
Yes
Yes
Ability to
add/modify these
rules by business
to take care of
future regulation
changes
Since US FATCA regulations
might release updates &
changes, it may need flexibility
to change the indicia,
aggregate balance rules and
remediation process without
heavy investment of time and
cost
The agile Rules Engine
enables users to manage and
modify compliance rules
without any coding skills. It
has configurable library of re-
usable rules that can be used
for future regulatory changes.
No Yes
Review and
Remediation
Management
FATCA compliance needs a
robust review and remediation
process to be in place for case
management capabilities.
Part of this is needed to bring
in transparency, consistency
and improving auditability.
Auto-case creation, de-
duplication checks, rule based
routing and escalations,
linking / tracking of related
cases until closure render
strong case management
capabilities.
No Yes
Alerts, Exceptions
and Escalation
Management
Critical elements are needed to
make informed, proactive and
intelligent decisions when the
issue originates and not when it
gets escalated as Non-
Compliance.
Rules based Alerts, roles
based escalations and
authority based exceptions
make the process much more
efficient and compliant
No Yes
Recalcitrant
Processing
Ability to define, identify and
decide on Recalcitrant
customers is a primary need for
a potent FATCA program
Collaboration based approval
process based on defined
rules & validations for
customer classification
enables entire workflow
automation of the
Recalcitrant process
No Yes

2. What is
needed
Why is it
needed
How do we
accomplish this
Core
Banking
System
Newgen
FATCA
Solution
Change of
circumstances
FATCA regulations need Automatic
triggering of business events & change
of customer status codes
Rules driven approach to automate and
proactively monitor the customer status
with alerts sent to the responsible
officers in the form of a dashboard.
No Yes
Track non-compliance
at customer &
account level
As per the IRS requirements FFI's need
to present track sheets for non-
compliant customers. FFI's need to have
a process and associated systems in
place for tracking and monitoring non-
compliant customers and account level
details so as to be informed and
compliant internally as well as externally.
The tool enables any non-compliance to
be tracked as per guidelines that have
been set in the FATCA process. It not only
highlights but also presents those non-
compliances proactively.
No Yes
Business Process
Management
FATCA needs FFI's to have flexible and
dynamic workflows to help compliance
managers and responsible officers
manage customer transactions across
the lifecycle of classified customers
through remediation and recalcitrant
status.
The tool includes investigations,
document collection and contact
management processes with in built
audit checks, notifications and
authorizations
No Yes
Document
Management
Document / evidence capture, linking
and de-linking, versioning, tracking and
archival capabilities while supporting the
FATCA data retention requirements are
critical elements needed for FATCA
compliance.
An integrated Document Management
system enables automatic creation of
electronic customer files with history of
communication documents archived
along with auditable versions at all touch
points.
No Yes
Communication
Management
Ability for relationship managers to
manage complex, multi-threaded high
net worth relationships with complete
accuracy and control.
Automated Template and Trigger driven
correspondences & communications to
all clients, reduces the manual effort
considerably.
No Yes
Audit Management FATCA regulations specify Bank's ability
to audit the classification as well as
remediation process
Tool enables setting audits on the
process lifecycle and proactively
presenting the transactional history for
all regulatory reporting
No Yes
Monitoring and
Investigation
Capabilities
Ability to provide alerts, notifications,
queuing and work management
along-with comprehensive audit trail
facilities are required to support
monitoring and investigation capabilities
With the Real-Time Reporting and
Dashboard tool, users can :
 View Pre-Configured Reports
 Modify Existing Customers
 Configure new reports using BAM
tool
The Tool comes with pre-configured
reports:
 Compliance Reports which need to
be sent to IRS/Local Govt. (IGA)
 Investigative Reports for monitoring
and tracking of entire Process
No Yes
Periodic Reviews FATCA needs regular periodic reviews on
all customer accounts to be able to
present the updated status report
whenever needed
Business Process Management
capabilities enable regular/scheduled
reviews which allow monitoring reports
to be presented to the responsible
officers of the Bank
No Yes
IRS / IGA reporting FATCA regulations put a lot of stress on
reporting guidelines which are needed
for IRS/IGA reporting
Pre-configured reporting formats
available as a part of the tool and ability
to generate specific formats as per
guidelines
No Yes
Future ready solution
extendible to other
country FATCA
regulations
FATCA has been an extensive and
extended regulation with many other
countries coming up with their own
versions E.g. UK FATCA is imminent in
near future.
Agile and flexible FATCA solution to take
care of the current as well as future
versions of FATCA without any hard
coded process framework
No Yes
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