Frequently Asked Questions
FIRE system includes a tracking mechanism for knowing the elapsed time since the request. Our sorting mechanism allows easy checking on long due requests for follow up actions to be taken.
Email notifications can be sent also to remind account managers/branch managers about required actions for account holders that have documents pending.
Does the system automatically identify the required documents needed by the account holders for both FATCA and CRS?
FIRE FATCA and CRS logic includes process for dealing with account holders that, based on regulation, require providing further documentation such as self-certifications, W8, W9 and other documents. The FATCA and CRS status is put on hold until the required documents are provided.
FIRE system includes a service to upload and view physical documents that are provided by clients as a mechanism to keep in a file the relevant documentation. The digital representation of the documents is saved inside our database.
Is the system multi institutions/branches (multi GIINS)? i.e., the users of a specific GIIN would only have access to the data of their authorized institution?
FIRE system can handle multiple institutions at once, and even institutions are belonging to separate jurisdictions. When generating the reports, the user can select the institutions that he wants to include, and our system will pick the right information for each, including GIINs.
The system is capable, also, of using the proper configuration that affects specific and behaviors based on jurisdiction configuration. For example, some jurisdictions may need to create separate XML files per countries and others may require a consolidated file.
Does the system automatically produces the required XML reports (specific jurisdictions schemas) based on the jurisdictions a user chooses?
FIRE system contains jurisdiction configuration that allows the generation of different XML files based on particularities that some jurisdictions apply to the standard XML schema.
Does the system track the interactions with the account holders? Notes on the client's case (i.e., calls to the account holders/conversations in the branch) with dates recorded?
Yes. The logic also includes the operations to record the history of the requests for documents that have been sent to the clients or notes from conversations with the account holder.
Does the system have MIS reports for CRS and FATCA in a form of dashboard and details? I.e. Reportable customers including their CIC, name, ID, nationality, country, etc...?
OPES FIRE Due Diligence System contains both a dashboard and a details grid that reports back to the user in a very simple manner statistics about the reportable accounts and other statuses such: non-reportable accounts, missing indicia accounts, high-value accounts, required documents accounts.
From the dashboard, the user can easily navigate to a grid with a summary of the accounts, and from there to a specific account details panel exposing all the relevant information for each account.
All these operations are ruled by our roles-based model, so only authorized users can access confidential information.
Does the system have configurable parameters/algorithms to adopt to business/regulatory changes/requirements?
OPES FIRE Due Diligence System is built with a BPMN (Business Process Modeling and Notation) technology that allows the easy configuration and changing of the core logic based on business or regulatory requirements. The heart of the logic for FATCA and CRS status definitions for individual and entity account holders, for the entities’ controlling persons and for the accounts, uses the mentioned technology.
Does the system process all combinations of accounts? i.e. multiple account holders such has individuals/entities/controlling persons?
Yes. There is no limit in the cardinalities that our system can take for the relations between accounts, account holders, and controlling persons. As examples, we can accept accounts where the account holder is just one individual, just one entity, or any combination and number of the two:
Accounts with 2, 3 or more entities being the owners, accounts with 2, 3 or more individuals, accounts with “n” number of individuals and m number of entities. The same applies to controlling persons.
We accept entities with 0 or n number of controlling persons. These combinations allow an individual or an entity also having any number of accounts.
The logic for FATCA and CRS include the analysis of the controlling persons for entities where their type requires so. The analysis includes looking for indicia for the controlling persons and the definition of the status of the entities based on such.
Of course, once the entity status has been defined according to its controlling persons (along with the own entity information), this status is used to reflect on the status for all the accounts where the entities’ controlling persons are owners.
Yes. From every pane in the system, the user can easily export all the information to an Excel format file. If required, other standard formats can be included as part of the proposal.
The UI allows the filling of missing indicia right on the screen (by authorized users), so there is no need to go back to the source system to proceed with the due diligence dictated by the regulations.
FIRE system includes a mechanism to set the due dates for each type of report and jurisdiction so interested parties can get an automated notification in the UI and via email when the due dates are close (the time frame can be configured also).
FIRE system includes two mechanisms for that. A complete security audit mechanism tracking all users’ activity, from the security perspective, and a full audit functionality to track any changes to critical information in the database including of course the actor who did the change, the type of change and the timestamp of the action.
Our system can connect to any external system to push changes applied. To properly set up this mechanism, we just need to implement the particularities of the API you expose to receive the changes. A direct change to known data sources is possible via standard database connections such as ODBC, JDBC, or so.
Are the Entity beneficial owners based on the entity type (Passive / Active) available in your system?
FIRE system contemplates the ingestion of the relevant beneficial owners for the entities and includes the logic defined in the regulation for assessing the status of controlling persons depending on the account balances, entity types and the indicia found.
This logic makes part of the configurable BPMN engine that the bank can customize/enhance based on the bank’s needs or future changes in the regulation.
OPES FIRE system includes the actions defined in the regulation in regards to paper search on files and relationship managers’ input when dealing with preexisting individual accounts.
The due diligence process will be put on hold if a paper search or relationship manager input is required. Once the results of the paper search or the concept of the relationship manager is input into the system, the process continues for determining the recommended FATCA or CRS status.
As part of our UI functionalities, we include powerful filters that allow an easy search by account status, range of balances, range of opening dates (preexisting, new accounts), type of account holders (individuals/entities), and other fields such account number.
Does the system have the functionality to send notifications internally i.e. to branches, compliance staff or other persons related to the FATCA/CRS process?
We have an easily configurable notification service that allows the definition of the events that require to be notified along with the recipient of such notifications and templates to configure the specific information and messages that need to be sent.
For example, the notification can be created to send all branch managers on a weekly basis all the account holders that have pending documents more than a certain timeframe. This is all easily configurable in a “set once and forget” mode.
Can your system automatically identify the status of each account? i.e. reportable, non-reportable, recalcitrant, etc...
That is the main goal of the system. Determine in an automated way all the statuses for the accounts, account holders, and controlling persons based on the actual information in the records and according to strict rules from the regulation.
No manual intervention is required at any step of the process, except for the input of required documentation, paper search on files or relationship managers’ concept.
For CRS, does the system create either multiple XML files for each reporting country or a single XML file with all consolidated countries to be sent to the local tax authority?
Yes. Based on the configuration, either single XML files per country or one consolidated XML file can be generated for the case of CRS.
As part of the logic stated by the regulation, the system includes the steps to allow a curing process for such account holders that can provide documentation that states that their status is different from the ones calculated by the workflow engine.
Part of the statuses that the system can apply to account holders includes RECALCITRANT and UNDOCUMENTED accounts when no proper documentation is provided.
FIRE system is built with a micro-services architecture allowing the replication of service instances depending on the demand. If higher throughput or higher volume of data needs to be processed, each service can be replicated as needed in the same server or in a cluster of servers.
Only critical services need to be replicated, reducing costs in hardware and total cost of ownership.
Does the system show an explanation of why an account was classified with a certain status i.e., reportable, or non-reportable?
We include a mechanism to help the user understand the particular path that an account took in the logic for getting to any status.
We understand the complexity of the regulation and the many variations that can happen, so we implemented this functionality so a clear explanation is exposed regarding why any status resulted.
Can your system identify any changes in the existing customer details if it belongs to any of the FATCA/CRS Indicia and flag such existing customers as FATCA reportable?
FIRE will analyze the changes from the account and if required “reclassify” the account as FATCA reportable or requiring a document.
Is your system flexible and customizable for any changes in the regulations and reporting requirements?
FIRE is regularly updated (remotely trough the maintenance) to stay current with the regulations and reporting requirements.
OPES FIRE system allows the users to correct, amend, void their XML reports for both FATCA and CRS.
Yes. OPES FIRE system has a full audit trail.