FATCA Dry-Run & Reconciliation
We execute a full dry-run of your FATCA reporting and perform detailed reconciliations (tie-outs) before go-live — expanding sampling, validating schema/logic, checking GL tie-outs, fixing defects, and issuing a clear go/no-go recommendation.
Who it’s for
- Reporting entities that completed Build & Configure and want assurance before live filings.
- Teams seeking strong evidence (results, logs, reconciliations) for reviewers, Internal Audit, and RO certification.
- Institutions aligning FATCA with QI and wanting consistent tie-out & defect handling across regimes.
Objectives of the dry-run
Expand Sampling
Scale up samples across classifications, account types, and edge cases to validate outcomes and controls.
Validate Consistency
Schema (XSD) checks plus cross-field and cross-system consistency; review of code sets and reference tables.
Prove Reconciliations
GL/tie-outs from source balances to 8966/local XML totals; exception log with root cause & fix path.
Scope of work
Sampling & Testing
- Risk-based and stratified sampling
- Re-performance of controls & reviewer checkpoints
- Negative/boundary tests for critical rules
Schema & Logic Validation
- XSD validation for XML outputs
- Cross-field checks (TIN/GIIN, classifications, balances)
- Lineage spot-checks & evidence completeness
Tie-outs & Reconciliations
- GL / sub-ledger reconciliations
- Totals by pool/classification vs. filings
- Variance analysis & materiality assessment
Defects & Fixes
- Defect register with severity/impact
- Root cause & remediation owner/date
- Retest results & acceptance criteria
Portals & Submissions (test)
- Portal readiness checks
- Test submissions where available
- Query handling playbook
Corrections Readiness
- Pre-agreed workflow for corrections/re-filings
- Receipt/ACK handling & audit trail
- Escalation & communication templates
How we work
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1) Dry-run plan & data cut
Agree sampling, materiality thresholds, and exact data cut; lock acceptance criteria with stakeholders/IA.
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2) Execute tests & validations
Run schema/logic checks, expand samples, and re-perform key controls; maintain live defect register.
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3) Reconcile & remediate
Complete GL/tie-outs, analyze variances, fix defects, and retest until criteria pass.
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4) Read-out & go/no-go
Reviewer-ready report, reconciliations pack, and a clear go/no-go recommendation — plus next-step plan.
Deliverables you receive
Dry-Run Results Pack
Sampling plan & outcomes, schema/logic validations, evidence checks with screenshots/logs.
Reconciliation Sheets
GL/tie-outs, pool/class totals, variance analysis, materiality & sign-off trail.
Defect Register & Fixes
Severity, root cause, remediation status, retest results, acceptance criteria met/not met.
Go/No-Go Memo
Formal recommendation with residual risks and mitigations for go-live.
Corrections Playbook
Pre-approved workflow for corrections/re-filings, ACK tracking, and query handling.
RO Brief Check (optional)
Short-form note to support the RO ahead of certification.
Options & combinations
- Independent or with Internal Audit: Align sampling, ratings, and documentation to your IA methodology.
- QI alignment: Run a coordinated dry-run across FATCA & QI to reuse reconciliations and evidence.
- Automation add-on: Lightweight scripts/dashboards to repeat key validations & KRIs each cycle.
What’s next
Go-Live & Submission
Final filings, receipts/ACKs, authority queries; corrections if needed.
Handover & Certification Support
Operating handbook, training, RO brief check and certification support.
Voluntary FATCA Review (optional)
Independent, sampling-based review for added assurance.