102880 – Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Electronic Record Search: Curing Indicia

There may be occasions when the electronic record search gives indications of residence in a Reportable Jurisdiction that the financial institution considers may be incorrect. In such circumstances the financial institution may take steps to ‘cure’ the information before treating the Account Holder as a Reportable Person.

Where the financial institution holds information about the Account Holder that includes any of

a. A current mailing address in a Reportable Jurisdiction,

b. One or more telephone numbers in a Reportable Jurisdiction (and, for DAC/CRS, no telephone number in the jurisdiction of the reporting FI),

c. Standing instructions, to transfer funds to an account maintained in a Reportable Jurisdiction (other than a Depository Account in the case of the DAC/CRS), or

d. A currently effective power of attorney or signatory authority granted to a person with an address in a Reportable Jurisdiction, thenthe financial institution must obtain a self-certification from the Account Holder to establish the jurisdiction of residence.

the financial institution must obtain a self-certification from the Account Holder to establish the jurisdiction of residence. The financial institution can rely on self-certifications it has previously reviewed and maintained a record of, but, in either case, the self-certification must be supported by Documentary Evidence. If the self-certification supported by Documentary Evidence establishes that the Account Holder is not a Reportable Person, then the financial institution is not required to treat the Account Holder as a resident in a Reportable Jurisdiction.

The self-certification obtained as part of the curing procedure does not need to contain a definitive confirmation that an Account Holder is not resident in a particular jurisdiction. Provided the self certification positively identifies the jurisdictions where the Account Holder is resident it can be taken that the Account Holder is not resident in any other jurisdiction.

Where a financial institution has contacted an Account Holder for a self certification but the Account Holder has not responded, the account should be treated as undocumented 90 days after initiating contact. The 90 day period is to allow the Account Holder sufficient time to respond to the request for information. In such circumstances, the financial institution must contact the Account Holder at least annually to obtain the self-certification.

The information in d. above may arise in circumstances where the Account Holder cannot provide a self-certification. In such a case, the financial institution may rely on Documentary Evidence that establishes the Account Holder’s non-reportable status.