Build Package: FATCA Operating Model & Data Implementation

Author: Alexander Fölsche, CPA (US), Wirtschaftsprüfer (Germany), Swiss Licensed Audit Expert

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

Scope: FATCA governance, due-diligence design, TIN processes, data model and mapping, validations, dry-run testing, remediation planning and go-live support for Model 1 and Model 2 FATCA reporting.

Who this is for

  • FFIs that completed Starter status, GIIN and 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: 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 and RACI, indicia and curing process, source-to-target mappings, validations, and a full dry-run before first filing.
  • Enterprise implementation: multi-system mappings, exception handling and corrections workflow, evidence packs, GL/ledger tie-outs, portal onboarding, and go-live support.

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, and TIN campaign design — see Target Design.
  • Data model & mappings: KYC/core/portfolio data 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

1) Governance & Controls

Enterprise details: Target Design

  • FATCA Policy, Annex-I due-diligence standard, and change-of-circumstances procedure.
  • RACI for RO/Compliance, Operations and IT, maker–checker controls, control calendar and KRIs.
  • Training kit for Front/RM, Operations and IT.

2) Due-Diligence Design

Enterprise details: Target Design

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

3) Data Model & Technical Mapping

Enterprise details: Build & Configure

  • Field-level dictionary for customer, account, balances, income, U.S. TIN/DOB, controlling persons and look-throughs.
  • Source-to-target mapping to local FATCA XML for Model 1 or Form 8966 / IDES for Model 2.
  • Validation rules, error handling and 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 for Model 1 or IDES readiness for Model 2, receipts/ACKs and corrections plan.
  • Operating handbook, evidence templates, training, RO brief and BAU handover.

Scope & boundaries

Included: Governance and policies, due-diligence and TIN processes, data model and mappings, validations, dry-run and go-live support as required.

Not included: Starter registration and GIIN, annual filings and back filings (Run), and independent health checks (Assurance).

How it works

  1. Discovery & feasibility: workshops, document review, data availability, registration/portal needs, feasibility memo and budget range — see Discovery & Feasibility.
  2. Target design: RACI, control calendar, KRIs, detailed mappings, exception handling and filing workflow — see Target Design.
  3. Build & configure: mappings, validations, evidence templates, XML outputs and portal onboarding — see Build & Configure.
  4. Dry-run & reconciliation: sampling, logic checks, tie-outs and remediation — see Dry-Run & Reconciliation.
  5. Go-live & submission: first filings, receipts/ACKs, corrections and BAU handover — see Go-Live & Submission and Handover & Certification Support.

Indicative timeline

Designed to fit a focused project window. Exact timing depends on business size, systems landscape, number of source systems, data quality and portal onboarding. Typical ranges and effort drivers are outlined on the implementation pages.

Prerequisites

  • Completed Starter package or equivalent internal setup, including GIIN and national portal / IDES readiness.
  • Access to KYC, core banking and portfolio data owners and sample exports.
  • Named stakeholders for Responsible Officer / Compliance, Operations and IT.

Helpful resources

Next steps

Ready to build your FATCA operating model?
Choose your jurisdiction on the Countries pages for pricing and local specifics. Add the Run package when you are ready to move from design/build to annual filings and back filings.