FATCA Discovery & Feasibility

Before you invest, we help you determine whether a FATCA implementation or redesign is appropriate, what the true perimeter is, which data and registrations are required, how governance & reporting must be structured, and what timeline/budget is realistic.

Who it’s for

  • Banks and other FATCA reporting entities evaluating first-time implementation or a process redesign.
  • Institutions with recent changes in products, systems, outsourcing, or group structure and need to confirm applicability & effort.
  • Teams seeking a clear, reviewer-ready plan that aligns governance, data, IT, and reporting deliverables from day one.

What we assess

Applicability & Perimeter

  • Entity classification, product & account landscape
  • Withholding & reporting touchpoints
  • Group/branch setup & dependencies

Data & IT Readiness

  • US indicia, TIN/GIIN capture & data quality
  • Source systems, interfaces, mapping to 8966/local XML
  • Exception handling, logs, evidence trail

Governance & Controls

  • RACI/roles, control calendar, KRIs
  • Procedures, reviewer checkpoints, training
  • Escalation & remediation workflow

Deliverables you receive

Feasibility Memo

Clear yes/no with rationale, perimeter definition, and regulatory registrations required (GIIN & local portals).

Data & Process Gap List

Field-level data requirements, quality gaps, process/control gaps, and dependencies on IT or third parties.

Plan, Timeline & Budget Range

Right-sized roadmap with phases, responsibilities, milestones, and an indicative fixed-fee proposal.

How it works

  1. 1) Scoping call & document drop

    Agree objectives and perimeter; we review org charts, product lists, data dictionaries, current procedures, and prior filings (if any).

  2. 2) Workshops & walk-throughs

    Process walk-throughs across onboarding, indicia checks, mapping, validations, and submission; governance & control interviews.

  3. 3) Analysis & options

    We map applicability, quantify gaps, outline options (incl. QI alignment if desired), and estimate effort/timeline.

  4. 4) Read-out & next steps

    Reviewer-ready feasibility memo, prioritized action list, and a proposed implementation/redesign plan with budget range.

From feasibility to execution

Once feasibility is confirmed, we can continue seamlessly into the implementation program:

Target Design

Operating model, RACI, control calendar/KRIs, 8966/local XML mapping and validations, exception handling.

Build & Configure

Mappings & schema checks, evidence templates, portal onboarding/registrations, training materials.

Dry-Run → Go-Live → Submission

Sampling, tie-outs, fixes, final filings & acknowledgements; corrections/re-filings if needed; handover & RO support.

Optional add-ons

  • Quick data sampling: narrow sample to validate key fields (TIN/GIIN, classifications, balances) before committing to build.
  • Portal readiness check: local portal registration, test submissions, receipt handling, and support model.
  • Internal Audit alignment: co-sourced approach using your rating scales and documentation standards.

Timeline & pricing

  • Typical duration: 2–4 weeks depending on perimeter and data availability.
  • Client effort: scoping call, structured document drop, 2–4 SME sessions, read-out.
  • Pricing: fixed-fee once scope is agreed; blended options if combined with QI alignment.

FAQ

Is this required before implementation?
No, but it de-risks the program. It ensures applicability, data readiness, and realistic timelines before committing budget.
Can you start from issues we already found?
Yes. If issues were identified (internally or via a review), we incorporate them and size the redesign accordingly.
Do you assist with registrations and portals?
Yes — we cover GIIN and local portal onboarding and can run test submissions where available.
Do you also support QI?
We can scope combined FATCA & QI alignment to reduce duplicate controls and streamline reporting.