FATCA Target Design (Operating Model, Data & Controls)

We define the future-state FATCA operating model with integrated governance, field-level data mapping for Form 8966/local XML, a practical control framework (calendar & KRIs), and clear exception/corrections workflows—ready to build.

Who it’s for

  • Reporting entities that completed Discovery & Feasibility or a Current-State Assessment and are ready to design the target model.
  • Teams seeking a reviewer-ready blueprint that aligns governance, data, IT, controls and reporting outputs end-to-end.
  • Institutions wanting optional QI alignment to reduce duplicate effort across regimes.

Governance is embedded throughout

Governance isn’t a silo—it's built into every component of the target design (RACI, control calendar, KRIs, reviewer checkpoints, escalation). If needed, we can also deliver a focused module: Governance Redesign.

Scope of the Target Design

Operating Model & Roles

  • RACI, handoffs, SLAs, reviewer checkpoints
  • Three-lines-of-defense integration
  • Training & competency requirements

Data Model & Mapping

  • Field-level mapping to 8966 / local XML
  • Validations, reference tables, code sets
  • Data lineage, evidence trail & logs

Controls & KRIs

  • Control calendar (design & operation)
  • KRIs/thresholds, alerts & sign-offs
  • Sampling approach & re-performance

Exception & Corrections Workflow

  • Issue intake, prioritization, ownership
  • Corrections/re-filings, receipts/ACKs
  • Audit trail & authority queries log

Portal & Registration Plan

  • GIIN/local portal onboarding steps
  • Test submissions where available
  • BAU support model & SLAs

Documentation & Training

  • Procedures, checklists, templates
  • Evidence packs & dossier structure
  • Role-based training plan

How we work

  1. 1) Design workshops

    Translate feasibility/assessment outcomes into target requirements; confirm scope, dependencies, and design principles.

  2. 2) Draft target model

    Produce RACI, control calendar & KRIs, field-level mapping/validations, exception/corrections playbook, and portal plan.

  3. 3) Review & hardening

    Walk-throughs with SMEs and Internal Audit; refine design details; agree acceptance criteria for build.

  4. 4) Build-ready handover

    Finalize the Target Design Pack with checklists and templates to move into Build & Configure.

Deliverables you receive

Target Operating Model Pack

RACI, process maps, handoffs/SLAs, training plan, reviewer checkpoints.

Mapping & Validation Specs

Field-level mapping to 8966/local XML, validations, code sets, lineage and evidence requirements.

Control Calendar & KRIs

Design & operating controls with KRIs, thresholds, and sign-off cadence.

Exception/Corr. Playbook

Issue intake to resolution, re-filings, receipts, and authority queries handling.

Portal/Registration Plan

GIIN/local portal onboarding steps, test submissions, BAU support model.

Build Acceptance Criteria

Definition of done for configurations, tests, evidence, and documentation.

Options & combinations

  • Independent or with Internal Audit: Align to your methodology (ratings, documentation, sampling).
  • QI alignment: Integrate pools/rates mapping, 1042-S/1042 tie-outs, and shared documentation.
  • Voluntary FATCA Review: If you want additional sampling/testing, add our FATCA Voluntary Review.

Next steps after Target Design

Build & Configure

Implement mappings/validations, evidence templates, portal onboarding, and training.

Dry-Run & Reconciliation

Sampling, schema/logic checks, tie-outs, fix & retest before go-live.

Go-Live → Submission → Handover

Final filings & ACKs; corrections/re-filings; RO brief check and certification support.