FATCA governance — roles, policies, and the annual control calendar
Strong governance keeps FATCA operations predictable, evidence-rich, and reviewer-ready. This guide defines roles & responsibilities, a lean policy stack, and a practical control calendar you can execute with limited resources.
Scope: Applicable to banks under Model 1 or Model 2 IGAs that act as FFIs and/or withholding agents.
Aligns with RO certification expectations and reviewer practice.
1) Roles and responsibilities (RACI-lens)
- Responsible Officer (RO): ultimate attestation; sponsors policy stack; approves issues/material failures and remediation; signs certification.
- Tax Lead (FATCA): owns procedures, control calendar, reporting dossier, GIIN monitoring, corrections; chairs monthly FATCA Ops call.
- Operations (Onboarding/Client Tax): runs W-8/W-9 lifecycle, renewals (T-90/60/30), change-in-circumstances, exception queue.
- IT/Data: maintains data dictionary, mapping for 8966/local schema, export jobs, validation gates, secure evidence storage.
- Compliance/Legal: policy governance, privacy/consent (esp. Model 2), record retention, breach/escalation protocols.
- Internal Audit / 2nd line: independent testing per plan; tracks remediation to closure.
2) Lean policy stack (what to publish and keep)
- FATCA Policy (top-level): scope, roles, IGA model, governance, retention, escalation, independence statements.
- Procedures: documentation lifecycle (W-8/W-9), GIIN monitoring, reporting (8966/local), corrections & re-filings, withholding agent interplay.
- Control calendar: who/what/when; KRIs; evidence artifacts; maker-checker sign-offs.
- Data & Privacy note: consent (Model 2), data exports, minimization/redaction, access controls.
Keep versions and change logs. Store PDFs in the FATCA dossier with a clear index.
3) Annual control calendar (baseline)
| Frequency | Control | Owner / Checker | Key artifact (evidence) | KRI (example) |
|---|---|---|---|---|
| Monthly | GIIN match to IRS FFI list; exceptions queue updated | Tax Ops / Tax Lead | GIIN tracker + match log + exceptions with closures | % unresolved exceptions > 30 days |
| Monthly | W-8 renewal queue (T-90/60/30) and expiries fallback | Onboarding / Tax Ops | Renewal tracker; comms; fallback decisions | # expired docs with payouts |
| Quarterly | Spot-tests of W-8/W-9 acceptance quality | Tax Lead / QA | Sample sheets (pass/fail) + remediation tasks | Acceptance fail rate by form type |
| Quarterly | Corrections & re-filings review (aging, receipts) | Tax Ops / IT | Corrections log; refiling tracker; receipts | % corrections > 30 days open |
| Annual | Reporting readiness (schema, mapping, dry-run) | IT/Data / Tax Lead | Data dictionary; validation summary; sign-off | Reject rate in prior year |
| Annual | RO certification pack assembly & sign-offs | Tax Lead / RO | RO dossier index; sign-off pack; briefing deck | Open issues at RO brief |
4) Committee cadence & reporting
- Monthly FATCA Ops call: KRIs (renewals, GIIN exceptions), open corrections, privacy issues.
- Quarterly governance update: trends, audit points, remediation status, tech changes.
- RO brief (pre-certification): executive summary, dossier heatmap, disclosures draft.
5) Evidence management (what passes review)
- Central FATCA dossier with stable paths; PDF/A where reasonable; bookmarked reports.
- Index/evidence map (file→control); versioning and change logs.
- Access control & privacy: PII minimization, redaction, least-privilege access.
- Retention schedule (e.g., 7 years) and secure archive procedures.
6) Issues, remediation, and validation
- Record findings with severity, owner, ETA; include clear remediation tasks.
- Track validation evidence (before/after, re-test, approvals) before closure.
- Escalate material failures to RO with disclosure wording prepared early.
Governance pack (templates)
Control calendar (XLSX), policy outline (DOCX), monthly KRI dashboard (XLSX).
Control calendar (XLSX), policy outline (DOCX), monthly KRI dashboard (XLSX).
Want a turnkey FATCA governance setup?
We tailor your policy stack, build the control calendar, and produce a reviewer-ready dossier.
We tailor your policy stack, build the control calendar, and produce a reviewer-ready dossier.