05.18 – Timing of reviews

For pre-existing accounts being reviewed the data being considered should be that which is held at the date of the review. However, if the Financial Institution has archived data from the point when the account is identified as reportable, then this may also be used, provided that any subsequent changes in circumstance are included in the review process.

Lower Value Accounts

The review of Pre-existing Accounts that are Lower Value Accounts at 30 June 2014 must be completed by 30 June 2016.

Pre-existing Lower Value Accounts that are identified as reportable are only reportable from the year in which they are identified as such.

Example 1

The due diligence procedures are carried out on a Lower Value Account during March 2015, and the account is determined as reportable. The Financial Institution is only required to report on the account information for the year ending 31 December 2015 onwards.

High Value Accounts

The review of Pre-existing Accounts that are High Value Accounts at 30 June 2014 must be completed by 30 June 2015.

A high-value account only becomes reportable in the year in which it identified as such. Following the revision of the dates applicable to the agreement, there is no requirement to report on pre-existing High Value Accounts for the year previous to which it is identified as being reportable.

Example 1

The due diligence procedures are carried out on a High Value Individual Account during April 2015, and the account is determined as reportable. The Financial Institution is required to report on the account for the calendar year 2015 and subsequent years only.

Where the balance or value of an account does not exceed $1,000,000 as of 30 June 2014, there is no requirement to undertake an enhanced review of these accounts until the balance has exceeded $1,000,000 at 31 December 2015 or 31 December of any subsequent calendar year.

If the account is high value on one of those dates the Financial Institution must perform the procedures described for High Value Accounts by 30 June of the following year.

Example 2

The balance on an Individual Account is found to be in excess $1,000,000 when reviewed on 31 December 2015. The account is not determined as reportable until 6 June 2016. The Financial Institution is only required to report on the account for the calendar year 2016 onwards.