A Fiduciary’s FATCA Compliance Program Policies (RO Certification Edition)

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This document sets out FATCA Compliance Program policies for fiduciaries connected to private wealth management structures and may be relied upon to fulfill the corresponding FATCA Responsible Officer (RO) Certification requirements relevant to Model 2 intergovernmental agreement (IGA) jurisdictions.

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This document sets out FATCA Compliance Program policies for fiduciaries connected to private wealth management structures and may be relied upon to fulfill the corresponding FATCA Responsible Officer (RO) Certification requirements relevant to Model 2 intergovernmental agreement (IGA) jurisdictions.

Per Section 8.01 of the 2017 FFI Agreement, Model 2 IGA entities qualifying as Foreign Financial Institutions (FFIs) must establish and maintain a FATCA Compliance Program, which must consist of “policies, procedures and practices”. Although many FFIs implemented the procedures and practices for FATCA compliance, not all adopted a set of policies interlinking them. This document provides such a set of policies intended to connect together the FATCA procedures and practices common to the fiduciary industry, while remaining flexible enough to accommodate plausible operational variations.

This document covers the compliance activities applicable solely to group entities commonly operated by, and the client structures commonly administered by, fiduciaries of private wealth management structures in Model 2 IGA jurisdictions. Accordingly, this document solely addresses the FATCA compliance duties of such entities and their commonly adopted FATCA classifications (including the sponsorship concept and Trustee-Documented Trusts (TDTs)).