FATCA / CRS – New Year's Resolutions

Amidst the chaos that seems to inevitably go hand in hand with the final weeks before submitting the annual FATCA / CRS reports to the local authorities (31st July in Gibraltar), we seem to find ourselves making the same resolutions regarding what we would do better or different next year in order to allow ourselves to spend more of this time during the Summer months thinking about the sun, sea and holidays (lockdown permitting of course…) than TINs, reportable values and making sure notifications have been sent out to everyone we are about to submit a report on.

The familiar thoughts and promises run through the mind as we commit to making an earlier start to the process, next year we resolve to:

• continue to progress and record our annual classification reviews throughout the year rather than waiting on third party classification requests, proactive rather than reactive being key;

• send out the 90-day notification letters to those individuals who appear to be reportable as soon as possible following the turn of the calendar year, thus avoiding the need to obtain verifications of any changes and run through the figures we intend to report at the last minute;

• make sure we inform all banks and third parties of any changes in entity classifications or the personal details / circumstances of any potentially relevant individuals at the earliest opportunity, giving ourselves good time to discuss and review this and any data the banks and third parties may also be intending to report;

• update our procedures and reporting manuals with any changes which may be required following any recent developments or updates to guidance notes, FAQs, general interpretations etc.;

• remind ourselves whether we actually committed our produces down to writing… or was that last year’s resolution???

So, with efficiency and workload balancing at the fore of everyone’s minds, this year more than any others, we make these commitments with renewed vigour and determination knowing that come this time next year, we could all finally be reaping the rewards of sticking to our FATCA / CRS new year’s resolutions…