Build Package: FATCA Operating Model & Data Implementation

Design and implement the governance, processes, and data pipeline to move from registration to reliable FATCA reporting — across Model 1 (local competent authority) and Model 2 (direct IRS via IDES).

This package is right-sized to your business and systems: from a boutique, case-by-case workflow for a handful of clients to a full-scale, multi-system implementation with dry-runs and go-live. The detailed subpages describe a maximal enterprise-style implementation for complex environments.

Who this is for

  • FFIs that completed Starter (status + GIIN + national/IDES setup) and now need an end-to-end FATCA operating model.
  • Groups seeking a consistent approach across Model 1 and Model 2 jurisdictions.
  • Institutions upgrading from ad-hoc spreadsheets to a controlled, auditor-ready process.

Right-sized delivery (from simple to enterprise)

  • Lightweight workflow (few clients): pragmatic, case-by-case due diligence, slim data extracts, and a simple mapping to the local FATCA schema or Form 8966.
  • Standard build: formal policies & RACI, indicia & curing engine, source-to-target mappings, validations, and a full dry-run before first filing.
  • Enterprise implementation (maximal solution): multi-system mappings, exception handling and corrections workflow, evidence packs, GL/ledger tie-outs, portal onboarding, and go-live support — as outlined on the detailed implementation subpages.

Outcomes

  • Governance baseline: policies, roles (RACI), control calendar/KRIs, and evidence requirements — see Target Design.
  • Due-diligence engine: indicia search, curing paths, change-of-circumstances handling, TIN campaign design — see Target Design.
  • Data model & mappings: KYC/core/portfolio to Model 1 national schema or Model 2 Form 8966/IDES, with validations and exception handling — see Build & Configure.
  • Dry-run completed: sample-based tests, schema/logic checks, GL tie-outs, and remediation — see Dry-Run & Reconciliation.

What you get (Deliverables)

1) Governance & Controls

Enterprise details: see Target Design.

  • FATCA Policy (global), Annex-I due-diligence standard, change-of-circumstances procedure.
  • RACI (RO/Compliance, Operations, IT), maker–checker controls, control calendar & KRIs.
  • Training kit (slides + facilitator notes) for Front/RM, Ops, and IT.

2) Due-Diligence Design

Enterprise details: see Target Design.

  • Indicia catalogue & electronic search strategy; RM checks for high-value accounts.
  • Curing playbooks (US indicia remediation, W-9/W-8 collection, citizenship/CLN handling).
  • TIN collection strategy (new vs. preexisting), reminder cadence, exception coding and monitoring.

3) Data Model & Technical Mapping

Enterprise details: see Build & Configure (incl. Testing).

  • Field-level dictionary (customer, account, balances, income, U.S. TIN/DOB, controlling persons, look-throughs).
  • Source-to-target mapping → local FATCA XML (Model 1) or Form 8966/IDES (Model 2).
  • Validation rules (mandatory fields, formats, consistency checks, high-value flags), error handling & corrections workflow.

4) Dry-Run, Go-Live & Handover

Enterprise details: Dry-Run & Reconciliation, Go-Live & Submission, Handover & Certification Support.

  • Sample-based tests, schema/logic checks, and GL/ledger tie-outs.
  • Portal submissions (Model 1) or IDES readiness (Model 2), receipts/ACKs, and corrections plan.
  • Operating handbook, evidence templates, training & RO brief; BAU handover.

Scope & Boundaries

  • Included: Governance & policies; due-diligence and TIN processes; data model & mappings; validations; dry-run; go-live support as required.
  • Not included: Starter (registrations & GIIN), annual filings/back filings (Run), independent health checks (Assurance).

How it works

  1. Discovery & feasibility: workshops, document review, data availability, registration/portal needs; feasibility memo + budget range — see Discovery & Feasibility.
  2. Target design: RACI, control calendar, KRIs; detailed mappings; exception handling; filing workflow — see Target Design.
  3. Build & configure: mappings/validations, evidence templates, XML outputs; portal onboarding — see Build & Configure.
  4. Dry-run & reconciliation: sampling, logic checks, tie-outs; remediate findings; go/no-go — see Dry-Run & Reconciliation.
  5. Go-live & submission (if part of Build scope): first filings, receipts/ACKs, corrections; then BAU handover — see Go-Live & Submission & Handover & Certification Support.

Indicative Timeline

Designed to fit a focused project window; exact timing depends on business size/complexity and systems landscape (number of sources, data quality, portal onboarding). Typical ranges and effort drivers are outlined on our implementation pages.

Prerequisites

  • Completed Starter (GIIN + national portal/IDES readiness) or equivalent internal setup.
  • Access to KYC/core/portfolio data owners and sample exports.
  • Named stakeholders for RO/Compliance, Operations, and IT.

Helpful resources

Next steps

Choose your jurisdiction on the Countries pages for pricing and local specifics. Add the Run package when you’re ready to move from design/build to annual filings and back filings.