FATCA Target Design (Operating Model, Data & Controls)
We define the future-state FATCA operating model with integrated governance, field-level data mapping for Form 8966/local XML, a practical control framework (calendar & KRIs), and clear exception/corrections workflows—ready to build.
Who it’s for
- Reporting entities that completed Discovery & Feasibility or a Current-State Assessment and are ready to design the target model.
- Teams seeking a reviewer-ready blueprint that aligns governance, data, IT, controls and reporting outputs end-to-end.
- Institutions wanting optional QI alignment to reduce duplicate effort across regimes.
Governance is embedded throughout
Governance isn’t a silo—it's built into every component of the target design (RACI, control calendar, KRIs, reviewer checkpoints, escalation). If needed, we can also deliver a focused module: Governance Redesign.
Scope of the Target Design
Operating Model & Roles
- RACI, handoffs, SLAs, reviewer checkpoints
- Three-lines-of-defense integration
- Training & competency requirements
Data Model & Mapping
- Field-level mapping to 8966 / local XML
- Validations, reference tables, code sets
- Data lineage, evidence trail & logs
Controls & KRIs
- Control calendar (design & operation)
- KRIs/thresholds, alerts & sign-offs
- Sampling approach & re-performance
Exception & Corrections Workflow
- Issue intake, prioritization, ownership
- Corrections/re-filings, receipts/ACKs
- Audit trail & authority queries log
Portal & Registration Plan
- GIIN/local portal onboarding steps
- Test submissions where available
- BAU support model & SLAs
Documentation & Training
- Procedures, checklists, templates
- Evidence packs & dossier structure
- Role-based training plan
How we work
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1) Design workshops
Translate feasibility/assessment outcomes into target requirements; confirm scope, dependencies, and design principles.
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2) Draft target model
Produce RACI, control calendar & KRIs, field-level mapping/validations, exception/corrections playbook, and portal plan.
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3) Review & hardening
Walk-throughs with SMEs and Internal Audit; refine design details; agree acceptance criteria for build.
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4) Build-ready handover
Finalize the Target Design Pack with checklists and templates to move into Build & Configure.
Deliverables you receive
Target Operating Model Pack
RACI, process maps, handoffs/SLAs, training plan, reviewer checkpoints.
Mapping & Validation Specs
Field-level mapping to 8966/local XML, validations, code sets, lineage and evidence requirements.
Control Calendar & KRIs
Design & operating controls with KRIs, thresholds, and sign-off cadence.
Exception/Corr. Playbook
Issue intake to resolution, re-filings, receipts, and authority queries handling.
Portal/Registration Plan
GIIN/local portal onboarding steps, test submissions, BAU support model.
Build Acceptance Criteria
Definition of done for configurations, tests, evidence, and documentation.
Options & combinations
- Independent or with Internal Audit: Align to your methodology (ratings, documentation, sampling).
- QI alignment: Integrate pools/rates mapping, 1042-S/1042 tie-outs, and shared documentation.
- Voluntary FATCA Review: If you want additional sampling/testing, add our FATCA Voluntary Review.
Next steps after Target Design
Build & Configure
Implement mappings/validations, evidence templates, portal onboarding, and training.
Dry-Run & Reconciliation
Sampling, schema/logic checks, tie-outs, fix & retest before go-live.
Go-Live → Submission → Handover
Final filings & ACKs; corrections/re-filings; RO brief check and certification support.