Publication 5262 – QI Portal
Continuing the burst of activity, what better way to start a new year, than with a new QI, WP & WT portal and its bed time reading material, Publication 5262, which of course goes hand in hand with the new QI Agreement,Revenue Procedure 2017-15 and our first blog of 2017, the various things to know about the USTax Regulations in 2017.
The new QI Portal Publication 5262 is only a mere 45 pages, thankfully, taken up of a lot of helpful screen shots to aid the reader and walking the reader through the process of registering and the use of the QI online system.
The previous single FATCA portal which QIs could use regarding FATCA, QI, WP and WT issues now have to use the dedicated QI system (the QI,WP and WT information has been removed from FATCA portal) and includes the new QDD regime. This does make some sense, making it easier for Responsible Officers (ROs) to keep on top of the maintenance and information relating to the FI’s details. However, at the same time with IRC Chapter 3 (QI) and IRC Chapter 4 (FATCA) becoming ever more entwined it doesn’t quite make complete sense, but overall, this probably is a good thing as we have come across a number of companies who are keeping the QI and FATCA regulations separate. We do hope that the IRS has learnt from the FATCA portal and the QI system doesn’t suffer the same issues.
The good news with the new QI Portal, is that when a user registers for the first time, it can use the identifier which they obtained from when they registered initially via the FATCA Portal, which will allow the pre-population of part of the information required in the QI/WP/WT system.
This new portal means that FIs and the compliance teams need to think about this operationally which should lead to additional/further training needed for the registered users as well as the compliance program needing to be updated with the new process, details and information that is contained in Publication 5262. The QI portal allows for the FI to have up to four registered users, meaning the company needs to decide if they wish to add users which should already contain the RO and Contact Person as authorised users (or if necessary, remove users).
The hope behind having a dedicated QI Portal is that by using the system, FIs should have a smoother process when applying and managing QI information. Applying for QI and renewing QI status is much like the paper version and FIs will have to supply supporting evidence of account opening procedures, business activity plus other forms, i.e. the SS-4 form, all of which can be uploaded to the “system”. The portal will also help FIs to easily edit and even withdraw applications or renewal before it is approved.
Overall, the change to a dedicated QI Portal shouldn’t lead to too much change for complying QIs and the key piece to take away from this is that to remain compliant, the QI needs to implement this change quickly and efficiently by training the necessary staff and updating the compliance program.
Subject Matter Expert
Stuart is one of the key researchers and curators of legislation within TConsult Ltd. He was born and educated in South Africa before moving to the UK. Since leaving college Stuart has worked in the financial industry for independent financial advisors. His experience helps TConsult expand our specialisms and industry knowledge. He is the curator of our GATCA Resource Library.