RCBC sent letters and due diligence forms to pre-existing clients to obtain their FATCA status and waiver of bank secrecy laws. RCBC also revised its account opening forms to capture U.S. indicia at the outset. Procedures for on-boarding of new clients were enhanced to equip client-facing personnel the skills required to identify U.S. persons. RCBC likewise enhanced its IT system to capture the required FATCA information and documents from new clients beginning July 1, 2014.
The IGA provides the manner and level of due diligence required of FFIs to identify U.S. persons. In compliance thereof, the Bank implemented a number of measures, including but are not limited to:
Enhanced due diligence for high value accounts that included: electronic record search of financial accounts for US indicia; paper record search of financial accounts for US indicia; and inquiries with relationship managers.
RCBC also participated in submission testing conducted by the IRS.
RCBC rolled out a new self-certification form for non-U.S. entity clients. This form replaced the U.S. IRS Form (W-8BEN-E) to give its clients a more comprehensible form that covers all mandatory information required under FATCA. The FATCA status tags in the Bank’s core system are likewise updated to comply with the reporting requirements of the IGA.