102320 – Reportable Information: Reasonable Efforts to Obtain

Where a financial institution does not hold information in its records on either the Account Holder’s taxpayer identification number or date of birth, it is expected to make reasonable efforts to obtain the information by the end of the second calendar year following the year in which the account is identified as reportable. Such attempts must be made at least once a year. 

Reasonable efforts require genuine attempts to obtain the information and would include all or any of the following:

  • Contacting the Account Holder by mail, in-person or telephone and could include requests made as part of other documentation;
  • Electronic contact such as facsimiles or e-mail;
  • Reviewing electronically searchable information maintained by a related entity in accordance with the aggregation principles.

Reasonable efforts do not require the closing, blocking or transferring of an account, nor conditioning or otherwise limiting its use, simply because the Account Holder does not comply with a request for this information. 

Reasonable efforts may continue to be made after the above mentioned period if the financial institution so chooses.