Build Package: QI Operating Model, Documentation & Data Implementation

Design and implement the governance, documentation flows, withholding controls, and data pipeline you need to operate as a Qualified Intermediary — from day-to-day W-8/W-9 handling to year-end 1042-S / 1042 reporting.

Scope scales with your business and systems: from a streamlined setup for a small client base to a full multi-entity, multi-system implementation. Country-specific pricing is listed on the Countries pages.

Who this is for

  • Custodians, brokers, banks, asset managers, and trust companies that completed QI Starter (QI Agreement & portal) and now need an end-to-end operating model.
  • Firms upgrading from ad-hoc spreadsheets to a controlled, auditor-ready process for Chapter 3 withholding and Forms 1042-S / 1042.
  • Groups seeking consistent execution across entities and booking locations.

Outcomes

  • Governance baseline: policies, RACI, control calendar, KRIs, and evidence standards tailored to QI obligations.
  • Documentation engine: W-8/W-9 intake & validation, renewals, presumption rules, and exception handling.
  • Withholding & reporting design: rate determination, pooling, allocations, and a mappable data model to 1042-S / 1042.
  • Dry-run completed: end-to-end test from documentation to mock 1042-S files and reconciliations.

What you get (Deliverables)

1) Governance & Controls

  • QI Policy (global), documentation standard (W-8/W-9), renewal cadence, and undocumented-account handling.
  • RACI for RO/Compliance, Operations, Front Office, IT; maker–checker controls and control calendar with KRIs.
  • Training kit (slides + facilitator notes) for client-facing teams and operations.

2) Documentation & Pools

  • W-8/W-9 intake & validation rules (reasonableness, treaty eligibility/LOB checks, capacity & chapter indication).
  • Pooling model (beneficial owner pools, non-pooled, unknown/undocumented), renewals & expiries, presumption rules, and backup withholding triggers.
  • Exception queues and service-level handling (rejects, expiries, cures).

3) Withholding & Rate Determination

  • Income/recipient coding, chapter 3 vs. chapter 61 logic, treaty rate mapping, limitation-on-benefits checkpoints.
  • Event-time controls for distributions, accruals, adjustments, and make-wholes.
  • Optional scoping for QDD/871(m) if derivatives are in scope (handled as an add-on).

4) Data Model & Technical Mapping

  • Field dictionary: client & account attributes, form metadata, treaty data, income events, withholding, and allocations.
  • Source-to-target mapping → 1042-S (boxes, recipient codes, exemption codes, chapter indicator) and Form 1042 tie-outs.
  • Validation rules (mandatory fields, formats, consistency checks), exception handling, and audit trail requirements.

5) Dry-Run & Reconciliations

  • Sample-based mock 1042-S generation; schema & logic checks; error handling walkthrough.
  • Reconciliations: pool totals ↔ withholding ledgers ↔ GL; variance analysis and remediation plan.
  • Go-live checklist and operating handbook for BAU.

Right-sized delivery (from simple to enterprise)

  • Lightweight build: small client base, simplified pools, manual validations with templated controls.
  • Standard build: formal policies & RACI, automated validations, data mapping to 1042-S, dry-run prior to first year-end.
  • Enterprise implementation: multi-system mappings, automated exception queues, dashboards, and multi-entity roll-ups.

Scope & Boundaries

  • Included: Governance & policies; documentation flows; pooling & rate determination; data model & mappings; validations; dry-run & reconciliations.
  • Not included: QI Agreement & portal setup (Starter), live 1042-S / 1042 year-end and daily withholding operations (Run), 3-year Periodic Review (Assurance).

How it works

  1. Discovery: products/flows, documentation posture, current pools, data sources, booking locations.
  2. Design: governance & controls, W-forms flows, pooling & rate mapping, field dictionary.
  3. Configure: mappings, validations, exception queues; reports & dashboards as needed.
  4. Dry-run: mock 1042-S, reconciliations, findings, and go-live checklist.

Indicative Timeline

Built to fit a focused project window; timing depends on number of entities, products, and source systems, as well as documentation clean-up needs. Pricing and SLAs per jurisdiction are on the Countries pages.

Prerequisites

  • Completed QI Starter (QI Portal live; RO/POC designated) or equivalent internal setup.
  • Access to product owners, documentation teams, and data extracts (events, forms, withholding).
  • Named stakeholders for RO/Compliance, Operations, and IT/Reporting.

Helpful resources

Next steps

Confirm your jurisdiction on the Countries pages for pricing and local details. When you’re ready to move to live operations and filings, add the QI Run package.